Inherent power to quash criminal proceedings after exoneration on the same facts defeats the need to seek discharge first.

Where an adjudicating authority has already exonerated a person on the same facts and material, continuation of criminal proceedings serves no useful purpose and may be quashed by the High Court in exercise of its inherent jurisdiction. The Court also clarified that Section 245(2) of the Code of Criminal Procedure, 1973 does not require the person to first seek discharge before the Magistrate in such a situation, because the High Court may directly intervene where the proceedings are not maintainable in law. The contention that the petitioner had to return to the trial court for discharge was rejected, and the objection based on Section 245(2) failed.

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Issues: Whether criminal proceedings could be quashed by the High Court after the adjudicating authority had exonerated the petitioner on the same facts and material, and whether the petitioner was first required to seek discharge before the trial court under Section 245(2) of the Code of Criminal Procedure, 1973.

Analysis: The adjudicating authority had examined the material and found no corroborative or incriminating evidence against the petitioner. The Court held that where the departmental or adjudicatory forum has exonerated a person on the same facts and evidence, continuation of criminal proceedings would serve no useful purpose. It further held that Section 245(2) of the Code of Criminal Procedure, 1973 does not compel a person in such a situation to first approach the Magistrate, because the High Court can exercise its inherent jurisdiction to quash proceedings that are not maintainable in law. The argument that the petitioner should be sent back to the trial court for discharge was rejected.

Conclusion: The objection based on Section 245(2) of the Code of Criminal Procedure, 1973 was rejected, and the criminal proceedings were held liable to be quashed in favour of the petitioner.

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