Section 482 proceedings cannot assess defences or conduct a mini-trial where prima facie material exists.

The petitioners, original Accused Nos. 1 to 3, invoked Article 226 of the Constitution and Section 482 of the Code of Criminal Procedure, 1973 (“CrPC”)—corresponding to Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023—to seek quashing of FIR No. 245 of 2021 registered at Talegaon-Dabhade Police Station under Sections 308, 336, 504, 506 read with Section 34 of the Indian Penal Code (“IPC”), and the resultant charge-sheet.

The FIR alleged that, on 22 July 2020 at about 11:30 p.m., three persons entered the ICU area of Sai Jeevan Hospital, abused and threatened Respondent No. 2 and others, allegedly disconnected the oxygen supply to the ICU, assaulted Dr. Mahendra Chavan, and threatened to kill him and shut down the hospital.

The petitioners contended that the FIR arose from matrimonial and property disputes between Dr. Mahendra Chavan and his wife, who was the daughter of Petitioner No. 1, and that the allegations were false and unsupported by hospital records, including the child’s clinical notes and oxygen-saturation records.

The State and Respondent No. 2 opposed quashing, relying on witness statements of nurses, hospital staff and watchmen, as well as material allegedly establishing the petitioners’ presence and involvement.

Whether the FIR and resultant charge-sheet disclosed a prima facie case under Sections 308, 336, 504, 506 read with Section 34 of the IPC against the petitioners warranting continuation of the criminal proceedings?

Whether the High Court, while exercising its inherent jurisdiction under Section 482 CrPC, could assess the petitioners’ factual defences, scrutinise the prosecution evidence in detail, or conduct a mini-trial to determine the correctness of the allegations?

Whether the circumstances justified exercise of the High Court’s inherent jurisdiction to quash the FIR and charge-sheet?

The Court applied Article 226 of the Constitution and Section 482 CrPC, now corresponding to Section 528 of the BNSS, which confer inherent jurisdiction to prevent abuse of process and secure the ends of justice, but do not permit the Court to conduct a mini-trial or undertake a meticulous evaluation of evidence at the quashing stage.

Relying on Central Bureau of Investigation v. Aryan Singh, (2023) 18 SCC 399, the Court reiterated that proceedings under Section 482 CrPC cannot involve a mini-trial or detailed scrutiny of evidence.

It further relied on Manik B. v. Kadapala Sreyes Reddy & Anr., 2023 SCC OnLine SC 2540, for the principle that quashing is appropriate only where, taking the allegations at face value, no case is made out; the Court should not examine the correctness of the prosecution material at that stage.

The Court found that the FIR contained specific allegations of threats, abuse, assault and disconnection of the ICU oxygen supply, and that the charge-sheet included statements of nurses, hospital staff and watchmen capable of prima facie supporting those allegations.

The petitioners’ presence at the hospital was also prima facie supported by the record.

Although the petitioners relied on delay in lodging the FIR, matrimonial and property disputes, and hospital records allegedly inconsistent with the oxygen-disconnection allegation, the Court treated these matters as factual defences requiring examination at trial rather than grounds for quashing.

Applying the rule against conducting a mini-trial under Section 482 CrPC, the Court held that it could not weigh the credibility of witnesses, assess the clinical records conclusively, or determine the truth of the competing versions at the preliminary stage.

The petition was accordingly dismissed, with liberty to the petitioners to raise their factual and evidentiary defences during the trial, including through cross-examination and defence evidence.