Inherent powers cannot be invoked to conduct a mini-trial or adjudicate disputed alibi defenses.

The petitioner, an Assistant Manager at Chhattisgarh Rajya Gramin Bank, sought the quashing of FIR No. 82/2025 and the subsequent Charge Sheet No. 110/2025.

The FIR was lodged by Respondent No. 4, alleging that on September 11, 2025, the petitioner and others unlawfully entered his house, assaulted him, and attempted to extort money and documents.

The petitioner contended that the case was a result of matrimonial discord between Respondent No. 4 and his wife, and that he was falsely implicated due to his professional intervention to prevent workplace harassment of the wife.

He further pleaded alibi based on CCTV footage.

Despite these representations, the police filed a charge sheet under Sections 296, 115(2), 351(3), 331(6), 119(1), 118(1), and 3(5) of the Bharatiya Nyaya Sanhita (BNS), 2023.

1. Whether the High Court, in exercise of its inherent jurisdiction under Section 528 of the BNSS, can quash criminal proceedings involving disputed questions of fact and pleas of alibi.

2. Whether the allegations in the FIR and the material collected during investigation prima facie disclose the commission of cognizable offences under the BNS, 2023.

The Court applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (corresponding to Section 482 of the CrPC), regarding the inherent powers of the High Court to prevent abuse of process.

It relied on the principle established in Vinubhai Haribhai Malaviya v. State of Gujarat (2019) 17 SCC 1 regarding the necessity of fair and impartial investigation under Article 21 of the Constitution.

The Court further applied the established doctrine that inherent powers for quashment must be exercised sparingly and only when allegations are inherently improbable or do not disclose a prima facie case.

The Court reasoned that at the stage of quashing under Section 528 of the BNSS, it cannot conduct a "mini-trial" or meticulously appreciate evidence.

While the petitioner raised a defense of alibi and alleged mala fide intentions rooted in matrimonial disputes, the Court observed that the prosecution had collected statements from the complainant and independent neighbors that prima facie supported the allegations of assault and house-trespass.

Regarding the challenge to specific sections of the BNS (such as lurking house-trespass under Section 331(6)), the Court held that whether the specific ingredients of these sections are met is a matter for the trial court to determine during the stage of evidence, not at the threshold.

The Court found that since the FIR and charge sheet contained specific overt acts attributed to the petitioner, the proceedings could not be termed a gross abuse of process.

The Court held that since the material on record disclosed a prima facie case of cognizable offences, the criminal proceedings must continue in accordance with the law.

It clarified that its observations would not influence the trial court’s final adjudication on the merits.