Section 482 quashing is unwarranted where the charge-sheet discloses offences and trial is advanced.

The applicants sought quashing of an FIR and prosecution arising from three term loans sanctioned to the Vadodara Mahanagar Palika Safai Sevak Co-operative Society.

The prosecution alleged that applicant No. 1, a chartered accountant, conspired with the Society’s office-bearers and bank officials to manipulate balance sheets, secure favourable loan recommendations, and divert loan proceeds to companies and firms associated with him and his family.

The charge-sheet alleged, among other transactions, transfers of funds to the applicant’s and his wife’s firms and companies.

The applicants argued that their work was professional accounting, that a bank pre-release audit had occurred, and that they were not public servants for purposes of the Prevention of Corruption Act.

At the time of the application, the trial was at an advanced stage and two witnesses had been examined.

Whether the FIR and charge-sheet disclosed a prima facie case against the applicants warranting continuation of the prosecution, or whether the proceedings should be quashed under Section 482 of the Code of Criminal Procedure.

Whether the applicants’ submissions—including that their role was limited to professional services and that they were not public servants—justified quashing the prosecution at that stage.

The Court considered the alleged offences under Sections 109, 120B, 420, 467, 468 and 471 of the Indian Penal Code and Sections 13(2) read with 13(1)(d) of the Prevention of Corruption Act.

It applied the principle that the High Court’s inherent jurisdiction under Section 482 CrPC is to be exercised sparingly and that, where the FIR and charge-sheet disclose prima facie cognizable offences, the Court should not conduct a mini-trial at the pre-trial stage. It relied on Rocky v. State of Telangana, 2025 (0) JX (SC) 1486, for these principles.

The Court found that the investigation materials prima facie indicated that loan proceeds had been transferred to entities associated with the applicants, including firms and companies linked to the applicant, his wife, and their daughter.

Those transactions, considered alongside the allegations of manipulated balance sheets and conspiracy, were sufficient at this stage to support continuation of the prosecution.

The Court did not accept the applicants’ submissions as grounds for quashing, particularly given that the prosecution involved multiple accused and the trial was already advanced.

In light of the governing restraint on exercising Section 482 jurisdiction, it declined to assess the evidence through a mini-trial.

It dismissed the application to quash the FIR and proceedings.