Inherent power to quash criminal proceedings applies where the record cannot reasonably support a conviction and prosecution would abuse process.

Section 482 CrPC may be used to quash criminal proceedings where the record contains no material capable of reasonably supporting a conviction and continuation would amount to abuse of process. The Court noted that the Sessions Judge's discharge power under Section 227 depends on consideration of the record and recorded reasons, which enables higher judicial review. It further held that the High Court's inherent jurisdiction is broad and can be exercised when the unrebutted material is so inadequate that no reasonable tribunal could sustain the charge, or where the prosecution would only cause harassment and waste judicial time. The quashing order was upheld and the appeals were dismissed.

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Issues: Whether the High Court was justified in quashing the criminal proceedings in exercise of its inherent powers on the ground that the material on record was insufficient to justify proceeding against the accused.

Analysis: Section 227 of the Code of Criminal Procedure, 1973 empowers the Sessions Judge to discharge an accused where, upon consideration of the record and hearing the parties, there is not sufficient ground for proceeding. The recording of reasons enables superior courts to examine whether the order is justified. Section 482 of the Code of Criminal Procedure, 1973 preserves the High Court's inherent power to prevent abuse of process and secure the ends of justice. That jurisdiction is wide and may be exercised where the material on record is so inadequate that no reasonable tribunal could predicate a conviction, and the continuation of proceedings would amount to harassment or waste of judicial time. The power is not confined by any rigid formula, and the court may assess whether the material, if unrebutted, could reasonably sustain the charge.

Conclusion: The High Court was justified in quashing the proceedings, and the dismissal of the appeals was affirmed in favour of the respondents.

Ratio Decidendi: The High Court may invoke its inherent power to quash criminal proceedings where the record discloses no material capable of reasonably supporting a conviction and continuation of the prosecution would amount to an abuse of process and defeat the ends of justice.

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