Prima facie criminal complaint over false medical certificate for tax deduction survives quashing at the threshold.

Detailed allegations that a medical certificate was knowingly issued to support a false tax deduction claim were sufficient to disclose a prima facie case at the quashing stage. The complaint specifically alleged that the claimant relied on the certificate, the claim was found false on enquiry, and the petitioner issued it to facilitate tax benefit and evade tax. The High Court held that such pleaded facts could not be rejected at threshold merely because the petitioner disputed reliance on a co-accused's statement; those factual and legal defences could be raised before the trial court. The proceedings were therefore not quashed.

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Issues: Whether the criminal complaint alleging issuance of a false medical certificate to facilitate wrongful tax deduction disclosed a prima facie case against the petitioner and could be quashed at the threshold.

Analysis: The complaint contained specific averments that the first accused had claimed deduction on the basis of the certificate issued by the petitioner, that the claim was found to be false on enquiry, and that the petitioner knowingly issued a false certificate to enable the first accused to obtain tax benefit and evade payment of tax. The Court held that, at the stage of quashing, the existence of detailed allegations was sufficient and the plea that the co-accused's statement could not by itself sustain conviction did not warrant quashing of the proceedings. The petitioner was left free to raise all factual and legal defences before the trial court at the appropriate stage.

Conclusion: The complaint disclosed sufficient material to proceed against the petitioner, and the request to quash the proceedings was rejected.

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