Proceedings manifestly motivated by malice and wage disputes may be quashed under Section 482 CrPC.

The complainant alleged that he and a friend were abducted and confined by the petitioner and his brother-in-law over unpaid wages, subjected to caste-based abuse, and released after their families paid ₹1,50,000.

The complaint was referred for registration of an FIR under Section 156(3) CrPC.

The Magistrate took cognizance under Sections 342, 343, 344 and 365 IPC and Section 3(1)(x) of the SC/ST Act.

The petitioner sought quashing, arguing, among other things, that he was implicated because of his relationship with the principal accused, the case arose from a wage dispute, and the alleged incident occurred outside the court’s territorial jurisdiction.

A co-ordinate Bench had already quashed proceedings against the principal accused.

Whether the cognizance order and resulting prosecution against the petitioner should be quashed under the High Court’s inherent powers as a mala fide prosecution arising from a wage dispute.

Whether the caste-abuse allegation attracted Section 3(1)(x) of the SC/ST Act where the alleged abuse occurred in a closed room rather than in public view.

Whether the asserted lack of territorial jurisdiction warranted quashing; this contention was recorded but not separately determined in the Court’s reasoning.

Section 482 CrPC empowers the High Court to quash criminal proceedings to prevent abuse of process.

Relying on State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335, the Court applied the principle that proceedings manifestly attended by mala fides or instituted with an ulterior motive to wreak vengeance may be quashed, corresponding to category 7 of the Bhajan Lal categories.

The Court also considered the public-place/public-view requirement it treated as necessary for the alleged offence under Section 3(1)(x) of the SC/ST Act.

The Court regarded the prosecution as an attempt to exert pressure in a wage-related dispute, noting that the petitioner’s alleged connection to the incident rested principally on his relationship with the main accused.

It found the account of the complainant being forcibly taken away from the brick kiln unconvincing and considered the caste-abuse allegation insufficient because it was said to have occurred in a closed room, not in public view.

Applying Bhajan Lal, the Court concluded that the prosecution was mala fide and its continuation would abuse the process of law.

It also relied on parity and judicial discipline because the cognizance order against the similarly situated co-accused had been quashed.

It quashed the Magistrate’s order dated 12 June 2015 and all prosecution arising from Maranchi P.S. Case No. 11 of 2014; the application was allowed.