Section 482 quashing is unwarranted where witness statements disclose a prima facie case requiring trial.

The petitioners, landlords of premises at 309, Bipin Behari Ganguly Street, challenged proceedings arising from a complaint that they had padlocked a toilet previously used by the opposite party no. 2 and other members of a Council occupying a room in the premises

The landlords had initiated ejectment proceedings against the occupants, and contended that the criminal complaint was retaliatory and that the charge sheet had been submitted mechanically

After investigation, a charge sheet was filed under Sections 290/114 of the Indian Penal Code and Section 3(za)(A) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989; the Special Judge took cognizance

The petitioners sought to quash the proceedings under Section 482 Cr.P.C.

1. Whether the material in the case diary and charge sheet disclosed a prima facie case against the petitioners warranting continuation of the criminal proceedings

2. Whether the High Court should exercise its inherent jurisdiction under Section 482 Cr.P.C. to quash the proceedings as allegedly false, retaliatory, and an abuse of process

Section 482 Cr.P.C. preserves the High Court’s inherent power to prevent abuse of process and secure the ends of justice, but that power must be exercised sparingly and with circumspection.

Relying on Neeharika Infrastructure Pvt. Ltd. (as cited in the judgment), the Court stated that criminal proceedings should not ordinarily be scuttled at the initial stage and that, when considering a quashing request, the Court should not assess the reliability or genuineness of the allegations or conduct a mini-trial.

The proceedings under challenge arose under Section 3(za)(A) of the SC/ST (Prevention of Atrocities) Act, 1989 and Sections 290/114 IPC.

The case diary included witness statements, including that of the premises’ caretaker, indicating that the complainant and other Council members had previously been permitted to use the toilet and that a padlock was later put on it, preventing their access.

The Court considered this material sufficient to disclose a prima facie case.

The pending ejectment dispute and the petitioners’ claim that the complaint was retaliatory did not justify weighing the truth of the allegations at the quashing stage; their genuineness was for determination at trial.

The revision was dismissed, the interim order was vacated, and the trial court was directed to proceed expeditiously and conclude the trial in accordance with law, uninfluenced by the High Court’s observations.