Inherent powers cannot be invoked to quash proceedings where allegations prima facie disclose the commission of cognizable offences.

The petitioner, previously employed as a driver by Respondent No. 2 (the complainant), was accused of unauthorized entry into the complainant's residence on February 5, 2026.

The prosecution alleged that the petitioner utilized his prior knowledge of the premises and the location of the house keys to enter the residence with the intent to commit theft

The complainant and his wife stated that the house was found locked from the inside, and upon forced entry, the petitioner was suspected of stealing Rs. 8,890/-

Consequently, FIR No. 0157/2026 was registered at Police Station Sarkanda for offences under Sections 331(3) and 305(a) of the Bharatiya Nyaya Sanhita (BNS).

Following the submission of a charge-sheet on February 13, 2026, the trial court took cognizance of the matter on February 17, 2026

The petitioner approached the High Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), seeking to quash the FIR, charge-sheet, and cognizance order, asserting false implication due to prior animosity

1. Whether the material available on record discloses a prima facie case against the petitioner to justify the continuation of criminal proceedings

2. Whether the High Court should exercise its inherent jurisdiction under Section 528 of the BNSS to quash proceedings based on pleas of factual improbability and alleged malice

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which preserves the inherent powers of the High Court to prevent abuse of the process of law

It relied on the settled legal principle that inherent jurisdiction must be exercised sparingly and with circumspection, reserved for cases where allegations are patently absurd or no offence is disclosed

The Court further applied the doctrine that at the stage of quashing, the High Court is not required to conduct a "meticulous examination of evidence" or adjudicate the veracity of rival claims, as these are matters strictly reserved for the trial

The Court evaluated the charge-sheet and found that the prosecution's case was grounded in the petitioner’s prior acquaintance with the complainant and the specific allegation that he was found inside the premises checking valuables

The Court reasoned that because the petitioner was well-acquainted with the house and the security arrangements (keys), and given the missing amount of Rs. 8,890/-, the allegations could not be deemed "wholly baseless" at this preliminary stage

Regarding the petitioner's defenses—specifically the claim of prior enmity and the "concocted" nature of the FIR—the Court determined these were evidentiary issues that required a full trial for adjudication

The Court emphasized that improper investigation or mechanical cognizance claims do not warrant quashing when prima facie material exists

The Court concluded that since a prima facie case was disclosed from the material on record, the trial must proceed

the Court clarified that its observations were limited to the present petition and should not influence the trial court’s independent judgment