Statutory immunity protects forest officers from prosecution for acts performed in good faith while discharging official duties.

The applicants were serving as Beat Guards at the Sasan Gir Sanctuary and National Park

On January 13, 2016, while discharging their official duties, they intercepted the complainant for an alleged unauthorized entry into the restricted Endhaniya Forest Area, leading to the registration of a Forest Offence Register (FOR) against the complainant

Following this, the complainant lodged FIR I-C.R. No. 1 of 2017 at Mendarda Police Station, alleging that the applicants assaulted him with an axe and threatened him, invoking Sections 323, 324, 506(2), and 114 of the Indian Penal Code (IPC)

The applicants sought to quash the FIR, arguing it was a malicious prosecution intended to demoralize public servants

1. Whether the impugned FIR and consequential proceedings constitute an abuse of the process of law warranting quashment under the inherent powers of the High Court

2. Whether the applicants are protected from prosecution under Section 60 of the Wildlife (Protection) Act, 1972, for actions performed in good faith while discharging official duties

The court primarily applied the inherent powers of the High Court under Section 482 of the Code of Criminal Procedure, guided by the principles for quashing FIRs established in State of Haryana v. Bhajan Lal, particularly regarding proceedings instituted with mala fide intentions or ulterior motives

It further relied on Section 60 of the Wildlife (Protection) Act, 1972, which grants immunity from prosecution to government officers for acts done in good faith under the Act

The court also examined the statutory requirements for voluntarily causing hurt and criminal intimidation under Sections 323, 324, and 503 of the IPC

The court found that the complainant’s presence in the restricted forest area was undisputed, as evidenced by the prior Forest Offence Register

Because the applicants were public servants acting in their official capacity to prevent illegal entry, their actions were protected under Section 60 of the Wildlife (Protection) Act

Upon reviewing the investigation material, the court noted a total absence of medical evidence or certificates to support the allegations of bodily injury required to sustain charges under Sections 323 and 324 of the IPC

Additionally, no material was found to satisfy the ingredients of criminal intimidation under Section 503

Linking these facts to the Bhajan Lal guidelines, the court reasoned that the FIR was likely a retaliatory measure, making its continuation a manifest abuse of the legal process

The court held that since the allegations were unsupported by medical evidence and the applicants were protected by statutory immunity for good-faith discharge of duty, the criminal proceedings were unsustainable

Rule was made absolute