Investigation disclosing cognizable offences cannot be quashed where allegations prima facie satisfy statutory ingredients.

The petitioner, a 68-year-old resident, sought the quashment of FIR No. 03 of 2023 registered at Police Station Pulwama for offences under Sections 353 (Assault or criminal force to deter public servant from discharge of duty) and 506 (Criminal intimidation) of the IPC

The FIR was lodged by the Tehsildar (Respondent No. 2), alleging that the petitioner harassed and threatened a Patwari during an official land demarcation exercise

The petitioner contended the FIR was a "malicious prosecution" and a "personal vendetta" because he had previously filed complaints against the Tehsildar for dereliction of duty regarding state land retrieval

Conversely, the State alleged the petitioner was an encroacher who went "berserk" to stop the legal demarcation, supported by witness statements recorded under Section 161 Cr.PC

1. Whether the inherent powers under Section 482 Cr.PC should be exercised to quash an FIR where the petitioner alleges malicious intent and absence of physical assault

2. Whether the allegations in the FIR and subsequent investigation disclose the commission of cognizable offences under Sections 353 and 506 IPC

Section 482 of the Cr.PC regarding the High Court's inherent powers to prevent abuse of the process of law

State of Haryana v. Bhajan Lal (1992), which established that quashing powers must be exercised "very sparingly and with circumspection"

Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra (2021), holding that a court cannot conduct an inquiry into the reliability of allegations if they prima facie disclose a cognizable offence

Substantive law applied included Sections 353 and 506 of the Indian Penal Code

The Court observed that there were conflicting versions of the incident: the petitioner alleged administrative vendetta, while the respondents provided evidence of obstruction and intimidation supported by a site plan and witness statements

The Court reasoned that at the Section 482 stage, it cannot conduct a "mini-trial" to evaluate the veracity of evidence or the reliability of allegations

Since the investigation records and the FIR prima facie contained the ingredients of the offences—specifically that the Patwari was obstructed and criminally intimidated while discharging official duties—the Court determined that the matter required a full trial

It noted that the petitioner's presence at the scene and his protests against the revenue officials were not denied, lending weight to the necessity of proceeding with the chargesheet

The Court vacated the interim directions and granted the prosecution liberty to file the chargesheet before the competent court

The petitioner was granted the right to raise the issue of non-constitution of offences during the stage of consideration of charges before the trial court