Unimpeachable evidence disproving allegations warrants quashing of criminal proceedings to prevent abuse of process.

The dispute originated on October 11, 2022, following an altercation between the complainant (a 77-year-old former Public Prosecutor) and one Sourav Sen regarding a damaged entrance door and scooter parking at an apartment complex

The complainant alleged that the appellants joined the fray, manhandled him by targeting his pacemaker, assaulted his family members, and issued dire threats

Following an investigation, a chargesheet was filed under Sections 143, 341, 323, 324, 504, 506, 509, 427, and 354 of the IPC

The appellants moved the Calcutta High Court for quashing of the proceedings.

While the High Court quashed the proceedings against the female co-accused (the wives of the appellants), it refused to grant relief to the three male appellants, leading to the present appeals

1. Whether the allegations in the FIR and the material collected during the investigation, including CCTV footage, prima facie constitute the alleged offences against the appellants

2. Whether the continuation of criminal proceedings against the appellants constitutes an abuse of the process of law, warranting exercise of inherent powers under Section 482 CrPC

The Court primarily applied the inherent powers of the High Court under Section 482 of the CrPC (now Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023) to prevent the abuse of judicial process

It relied on the illustrative categories for quashing established in State of Haryana v. Bhajan Lal, specifically where allegations do not constitute an offence or where the proceeding is maliciously instituted with an ulterior motive

It further applied the "four-step test" from Pradeep Kumar Kesarwani v. State of Uttar Pradesh, which mandates quashing when an accused relies on "sterling and impeccable" material that effectively refutes the factual basis of the accusations

The Court conducted a firsthand examination of the CCTV footage collected during the investigation, characterizing it as a "material piece of evidence" and "unimpeachable"

The footage demonstrated that the appellants were not present during the initial altercation and, upon arrival, acted as mediators to pacify the situation rather than as aggressors

The Court observed that the FIR and Section 164 CrPC statements contained vague, omnibus allegations that were directly dislodged by the electronic record

It noted that the High Court erred by failing to analyze this crucial electronic evidence and by creating an arbitrary distinction between the appellants and the quashed co-accused despite identical allegations

The Court determined the dispute was essentially a trivial neighborly disagreement to which a "criminal colour" was maliciously added due to prior animosity, fitting the Bhajan Lal categories of malicious prosecution

The Court held that the material on record failed to disclose the ingredients of the alleged offences and that the prosecution was a gross abuse of the process of law

Consequently, the Court quashed Chargesheet No. 135 of 2022 and FIR No. 150 of 2022 (Police Station Survey Park) insofar as they pertained to the three appellants