Inherent powers to quash criminal proceedings may apply where unexplained delay makes continued prosecution unjust and oppressive.

Inherent powers may be used to quash criminal proceedings where an inordinate, unexplained delay after the raid, coupled with the Public Prosecutor's view that the case was unfit for prosecution and the initial refusal of sanction by the Revenue Commissioner, makes continuation unjust and oppressive. On those facts, the prosecution had remained pending for a prolonged period without adequate justification, and its continuation was treated as an abuse of process. The criminal prosecution and the proceedings before the Special Judge were quashed.

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Issues: Whether criminal proceedings should be quashed in exercise of inherent powers in the peculiar facts and circumstances of the case.

Analysis: There was an inordinate and unexplained delay after the raid before further prosecutorial action was taken. The Public Prosecutor had consistently opined that the case was not fit for criminal prosecution, and the Revenue Commissioner had initially refused sanction. The prosecution had remained pending for a very long period, and continuing it at that stage was considered unjust and oppressive.

Conclusion: The criminal prosecution and the proceedings before the Special Judge were quashed.

Ratio Decidendi: Inherent powers may be exercised to quash criminal proceedings where the long, unexplained delay and the surrounding circumstances make continuation of the prosecution unjust and an abuse of process.

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