Section 482 inherent powers cannot be used to conduct a mini-trial where allegations disclose prima facie cognizable offences.

The applicant sought the quashing of FIR No. I-C.R. No. 141 of 2014, the subsequent charge-sheet, and the proceedings of Sessions Case No. 218 of 2015

The complainant (Respondent No. 2) alleged that the applicant, a neighbor, induced her under the pretext of marriage, drugged her with a cold drink at his office, and subjected her to repeated sexual intercourse over several years

She further alleged that the applicant took nude photographs and videos to maintain control over her, leading to the dissolution of her first marriage and coercing her to flee her second matrimonial home with Rs. 17,00,000 and ornaments

The applicant argued that the allegations were inherently improbable, noting that a prior statement by the victim under Section 161 of the CrPC in a related theft case contained no allegations of rape

The prosecution highlighted polygraph test results showing the applicant’s presence at relevant locations and call records indicating frequent contact with the victim

1. Whether the allegations in the FIR and the material collected during the investigation disclose a prima facie case against the applicant to justify the continuation of criminal proceedings

2. Whether the inherent powers of the High Court under Section 482 of the CrPC should be exercised to quash the proceedings on the grounds of inherent improbability or lack of credible evidence

The court primarily applied Section 482 of the Code of Criminal Procedure regarding the inherent powers of the High Court to prevent the abuse of the process of law

It relied extensively on the guidelines established in State of Haryana v. Bhajan Lal, which dictate that quashing is permissible only if allegations, taken at face value, do not constitute an offence or are inherently improbable

The court further referenced Pinakbhai Riddhibhai Desai v. State of Gujarat and Rocky v. State of Telangana, asserting that the High Court should not conduct a "mini-trial" or evaluate the truthfulness of evidence at the quashing stage

Additionally, the principle from State of Andhra Pradesh v. Vangaveeti Nagaiah was applied, noting that "strong suspicion" is sufficient to proceed to trial

The court rejected the applicant's contention that the victim's initial silence regarding sexual assault in her Section 161 CrPC statement warranted quashing the FIR.

It reasoned that such omissions are matters of evidence to be addressed through cross-examination during trial, not at the threshold stage

The court observed that the investigation produced significant corroborative material, including call data records between the applicant and the victim, medical history records, and a polygraph test indicating the applicant’s affirmative responses regarding his proximity to the victim during her alleged abduction

Applying the Bhajan Lal criteria, the court found that the allegations were not "patently frivolous, vexatious, or inherently improbable"

It concluded that since the FIR and charge-sheet disclosed the commission of cognizable offences, any detailed appreciation of the evidence would amount to an impermissible mini-trial, thereby encroaching upon the statutory duties of the trial court

The High Court held that the inherent powers under Section 482 CrPC must be exercised sparingly and only in exceptional cases, which the present matter did not satisfy

Consequently, the application for quashing the FIR, charge-sheet, and sessions case was dismissed, and the rule was discharged