Section 482 cannot quash proceedings where the FIR discloses a prima facie case requiring trial.

Respondent No. 2, a medical practitioner, was the husband of Petitioner No. 1 and related to the other petitioners by marriage. Owing to matrimonial and disputes concerning the management of a jointly held hospital, the parties had been residing separately since November 2019

On 27 May 2020, Respondent No. 2 alleged that the petitioners and an unidentified person assaulted him outside the hospital, causing simple and grievous injuries, including a fracture of the nose. He further alleged that the petitioners abused him and threatened to kill him

On the basis of his complaint and supplementary statement, C.R. No. 360 of 2020 was registered at Talegaon-Dabhade Police Station under Sections 143, 147, 323, 325, 504, 506 read with Section 34 of the IPC. After investigation, a chargesheet was filed.

The petitioners invoked Articles 226 and 227 of the Constitution and Section 482 of the CrPC, now corresponding to Section 528 of the BNSS, seeking quashing of the FIR and proceedings; alternatively, they sought deletion of Sections 143, 147 and 325 IPC from the chargesheet

1. Whether the FIR and consequential criminal proceedings arising from C.R. No. 360 of 2020 disclosed a prima facie case against the petitioners warranting interference under Section 482 CrPC/Section 528 BNSS?

2. Whether Sections 143, 147 and 325 IPC ought to be deleted from the chargesheet on the grounds that the alleged unlawful assembly was not established and the fracture injury could have resulted from a pre-existing injury?

The Court applied Section 482 of the Code of Criminal Procedure, 1973, corresponding to Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which confers inherent jurisdiction to prevent abuse of process and secure the ends of justice

Relying on Central Bureau of Investigation v. Aryan Singh, (2023) 18 SCC 399, the Court reiterated that disputed defences and evidentiary questions cannot ordinarily be adjudicated in a petition under Section 482

It further relied on Manik B. v. Kadapala Sreyes Reddy, 2023 SCC OnLine SC 2540, for the principle that quashing is justified only where, even accepting the prosecution case at face value, no offence is made out

The Court held that, while exercising this jurisdiction, it cannot conduct a mini-trial, assess the credibility of witnesses, or undertake a detailed evaluation of the prosecution evidence; the allegations and material must instead be examined to determine whether they disclose a prima facie case

The FIR contained specific allegations that the petitioners assaulted Respondent No. 2, abused him and threatened him in the presence of witnesses

The witness statements prima facie corroborated the complainant’s version, while the medical certificate recorded both simple and grievous injuries, including a fracture of the nose

The petitioners’ arguments that the unidentified fifth person had not been traced, that the incident arose from a matrimonial dispute, and that the fracture may have been pre-existing were treated as matters of defence requiring evidentiary assessment at trial, not grounds for quashing at the threshold

Since the prosecution material, taken at face value, disclosed a prima facie case and did not demonstrate that the proceedings were manifestly groundless, the Court held that exercising inherent jurisdiction would be impermissible

The petition seeking quashing of C.R. No. 360 of 2020, and alternatively deletion of Sections 143, 147 and 325 IPC, was dismissed

The petitioners were left at liberty to raise their defences during cross-examination or by leading defence evidence at trial