Article 142 powers justify quashing criminal proceedings where continuation would amount to abuse of process.

Although criminal proceedings disclosed a cognizable offence and had reached the stage of charge and trial, the Supreme Court held that the peculiar factual background, long-standing disputes, allegations of mala fides, and the interests of complete justice justified intervention under Article 142. The Court noted the usual restraint under Section 482 of the Code of Criminal Procedure in quashing FIRs and investigations, but found that continuation of the litigation would amount to abuse of process. The criminal proceedings arising from both FIRs, together with the charges founded on them, were quashed.

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Issues: Whether the criminal proceedings and the impugned High Court order were liable to be set aside in exercise of the Supreme Court's power to do complete justice, having regard to the peculiar facts, the allegations of mala fides, and the stage of the criminal cases.

Analysis: The material showed a long-standing dispute between the parties, multiple connected proceedings, and allegations and counter-allegations arising during the appellants' medical studies. The settled principles governing Section 482 of the Code of Criminal Procedure required restraint in quashing criminal proceedings where the FIR and investigation disclosed a cognizable offence and the matter had reached the stage of charge and trial. At the same time, the Court found that the peculiar factual background, the nature of the disputes, the surrounding circumstances, and the interests of complete justice justified intervention under Article 142 of the Constitution of India to end the litigation.

Conclusion: The criminal proceedings arising out of both FIRs and the charges founded thereon were quashed, and the appellants obtained relief.

Ratio Decidendi: Even where criminal proceedings disclose a prima facie case and are ordinarily not fit for quashing under Section 482 of the Code of Criminal Procedure, the Supreme Court may invoke Article 142 of the Constitution of India to quash them where continuation would amount to abuse of process and complete justice so requires.

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