Quashing criminal proceedings after charge-framing requires exceptional circumstances.

The complainant alleged that, at about 11:30 p.m. on 17 April 2021, the petitioners quarrelled with him while he was sleeping outside his house, abused and assaulted him with a stone, caused injuries, and threatened him.

Mundargi Police registered Crime No. 47/2021 and, after investigation, filed a charge sheet alleging offences under Sections 323, 324, 504 and 506 read with Section 34 of the IPC; the case proceeded as C.C. No. 737/2021.

The petitioners sought to quash the complaint, FIR, charge sheet and proceedings, relying in part on pending civil litigation and asserting false implication and insufficient material.

By the time the High Court considered the petition, the trial court had framed charges and set the matter down for trial, a fact not disputed by the petitioners.

1. Whether the criminal proceedings should be quashed under Section 482 Cr.P.C. (Section 528 BNSS) after charges had been framed and the case set down for trial.

2. Whether the petitioners’ contentions—including false implication, insufficient charge-sheet material and the pending civil dispute—established exceptional circumstances warranting quashing.

The Court considered its inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973, corresponding to Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in relation to the alleged offences under Sections 323, 324, 504 and 506 read with Section 34 of the Indian Penal Code, 1860.

It stated that courts are generally reluctant to quash criminal proceedings once charges have been framed and the matter is set for trial, and should be slow to interfere absent exceptional circumstances; disputed questions of fact are not to be determined in the exercise of Section 482 jurisdiction.

The Court referred generally to the Supreme Court’s decisions in a “catena of judgments” but did not identify specific authorities.

The charge-sheet material alleged that the petitioners quarrelled with the complainant, abused and assaulted him with a stone, caused injuries and threatened him.

The trial court had already considered the material, framed charges and set the case for trial; the petitioners did not dispute that procedural status.

Their claims of false implication, lack of evidence and connection to a civil dispute raised factual matters for trial and did not, in the Court’s view, demonstrate exceptional circumstances justifying the exercise of inherent jurisdiction.

Pending applications were disposed of as having become unnecessary, and the trial court was directed to proceed with the trial and decide the matter in accordance with law; the High Court’s observations were confined to disposal of the petition.