Scientific reports negating adulteration render criminal proceedings for cheating and criminal breach of trust legally unsustainable.

The police intercepted two tankers (CG 04 NJ 8382 and CG 04 NJ 8385) based on information that they contained furnace oil adulterated with water, sulfuric acid, and sodium hydroxide

The prosecution alleged that the petitioners extracted 7000 liters of genuine oil and replaced it with the chemical mixture to derive wrongful gain

Consequently, FIR No. 10/2023 was registered under Sections 420, 407, 408, 120-B, and 34 of the IPC, and a charge sheet was subsequently filed

The Judicial Magistrate First Class, Sakti, took cognizance and framed charges, a decision upheld by the Sessions Court in revision

However, a scientific test report from the Indian Oil Corporation Ltd. (IOCL) Laboratory at Korba, submitted during the proceedings, concluded that the furnace oil samples met prescribed BIS standards, confirming correct density and permissible water content

The petitioners moved the High Court to quash the proceedings, citing this exculpatory evidence and the absence of any complaint from the consignee or owner

1. Whether the criminal proceedings are sustainable when the foundational allegation of adulteration is contradicted by a scientific expert report

2. Whether the ingredients of Sections 420, 407, and 408 of the IPC are made out in the absence of a complaint from the victim or evidence of misappropriation

3. Whether the High Court can exercise its inherent jurisdiction to quash proceedings after the filing of a charge sheet and framing of charges

The court applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (the successor to Section 482 of the CrPC), regarding the High Court's inherent power to prevent abuse of process

It relied on the landmark categories established in State of Haryana v. Bhajan Lal (1992), which permit quashing when allegations are inherently improbable or do not prima facie constitute an offence

It further applied the principle from Anand Kumar Mohatta v. State (NCT of Delhi) (2019), which clarifies that inherent powers to prevent miscarriage of justice can be exercised at any stage, including after the charge sheet has been filed

The substantive elements of Sections 407, 408, and 420 of the IPC require proof of dishonest intent and misappropriation of entrusted property

The court reasoned that the entire prosecution case rested on the foundational allegation that the petitioners adulterated the furnace oil

The scientific analysis conducted by the IOCL Laboratory—an authorized specialized body—categorically proved that the oil density and water content were within BIS limits, thereby ruling out adulteration

The court observed that such expert scientific evidence carries significant weight and effectively demolishes the basis of the charges

Furthermore, the court noted that no complaint was lodged by the consignee, transporter, or owner alleging any loss or breach of trust, meaning the essential ingredients of "dishonest misappropriation" under Sections 407 and 408 and "cheating" under Section 420 were entirely absent

Following the Bhajan Lal guidelines, the court determined that the allegations were "inherently improbable"

It concluded that continuing the trial in the face of clear exculpatory evidence would be a "travesty" and a manifest abuse of the judicial process

The High Court quashed FIR No. 10/2023, Charge Sheet No. 26/2023, the order of cognizance dated 10.03.2023, the order framing charges dated 11.12.2024, and the revision order dated 20.05.2025 as they pertained to the petitioners

All proceedings in Criminal Case No. 222/2023 against Manoj Kumar Singh, Jaisram Chaudhary, and Aslam @ Abdul Salam were set aside