Pending civil disputes do not justify quashing prosecution where specific criminal acts are alleged.

The petitioners sought to quash proceedings in C.C. No. 18814/2019, arising from Crime No. 75/2019, for offences under Sections 341, 354, 447, 504 and 506 read with Section 149 of the IPC.

The prosecution alleged that on 22 February 2019 the petitioners trespassed onto premises associated with an educational trust, abused and threatened persons present, and that some petitioners restrained and dragged female staff members, thereby outraging their modesty.

The dispute between the parties also concerned competing trust deeds and rights to the property; civil proceedings were pending.

Police investigated and filed a charge-sheet; Section 354 IPC was added during the investigation.

Section 482 CrPC confers a limited power to prevent abuse of process; at this stage, the Court does not assess disputed facts or decide issues requiring trial.

The Court relied on Lalita Kumari v. State of Uttar Pradesh, (2014) 2 SCC 1, for the rule that registration of an FIR is mandatory where information discloses a cognizable offence.

It treated the alleged offences under Sections 341 and 447 IPC as cognizable and held that the earlier NCR did not bar a complaint and investigation concerning the same incident once cognizable offences were disclosed.

Allegations concerning restraint, trespass, threats, abuse and outraging a woman’s modesty, supported by witness statements, could not be resolved by weighing disputed evidence in a Section 482 petition.

The Court found that the complaint and charge-sheet identified a specific incident and contained allegations of wrongful restraint and trespass, as well as threats, abusive language and conduct directed at female staff members.

Witnesses had been cited and their statements recorded, so whether the alleged acts occurred—and whether they satisfied the ingredients of the offences—was a matter for trial, not summary determination under Section 482.

The Court rejected the NCR objection because the allegations included cognizable offences and the second complaint referred to the earlier complaint; it also noted there had been no suppression of that earlier complaint.

The pending civil disputes and contested property or trust rights did not, in the Court’s view, negate the alleged criminal acts or justify quashing the prosecution.

It rejected the contention that the NCR barred the subsequent complaint and declined to treat the case as merely a civil dispute.

The criminal petition was dismissed.