Inherent jurisdiction cannot replace statutory discharge remedies when criminal proceedings are challenged before evidence is recorded.

The High Court held that inherent jurisdiction to quash criminal proceedings should not be invoked at a pre-evidence stage when the accused has an adequate statutory remedy to seek discharge before the Magistrate. Because the matter had not reached the stage for consideration under section 245 of the Code of Criminal Procedure and the accused could still contest the prosecution evidence under section 244, the challenge was treated as premature. The Court found that factual questions should be tested before the trial court, and the availability of the specific discharge mechanism made recourse to section 482 inappropriate at that stage. The petition was therefore dismissed as premature.

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Issues: Whether the petition under the inherent jurisdiction was maintainable to quash criminal proceedings at the stage before evidence was recorded, when the accused had an available remedy to seek discharge before the Magistrate.

Analysis: The challenge was held to be premature because the case was at the stage preceding consideration under section 245 of the Code of Criminal Procedure, 1973. The accused were left free to contest the prosecution evidence at the stage of section 244 and to seek discharge under section 245(1) if no case was made out. The existence of this specific statutory safeguard was treated as a sufficient remedy, and the inherent power under section 482 was held not to be the proper course where the grievance depended on facts and circumstances to be tested in the trial court. The proceedings were therefore not quashed in exercise of inherent jurisdiction.

Conclusion: The petition under section 482 of the Code of Criminal Procedure, 1973 was not maintainable at that stage and was dismissed as premature, leaving the petitioners to pursue the statutory remedy before the trial court.

Ratio Decidendi: The inherent jurisdiction of the High Court should not be invoked to quash pending criminal proceedings when the accused has an adequate specific remedy under the Code to seek discharge before the trial court and the matter depends on factual evaluation at the proper stage.

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