Limited scope of charge quashing under CrPC: prima facie material supported abetment allegations, so the charge was restored.

Revisional and inherent jurisdiction under Sections 397 and 482 CrPC is limited at the stage of framing charge under Section 228; the court must only see whether the material on record, taken at face value, discloses the ingredients of the offence and raises a strong suspicion, not conduct a trial-like appraisal of evidence. Quashing is justified only in rare cases where the allegations are patently absurd, inherently improbable, barred by law, or amount to abuse of process. A civil dispute does not justify quashing where the materials disclose criminality. On the alleged abetment of suicide under Section 306 IPC, the suicide note and related materials, if accepted at face value, disclosed circumstances capable of abetment, so the charge was to be restored and the trial permitted to proceed.

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Issues: Whether the High Court was justified in exercising revisional and inherent jurisdiction to quash the charge under Section 306 of the Indian Penal Code, 1860 at the stage of framing of charge.

Analysis: The scope of interference under Section 397 and Section 482 of the Code of Criminal Procedure, 1973 is limited, particularly where the challenge is to an order framing charge under Section 228. At that stage, the court is not required to evaluate the evidence as if conducting a trial; it must only see whether the material on record, taken at face value, discloses the ingredients of the offence and creates a strong suspicion that the accused has committed it. Quashing is warranted only in rare cases where the allegations are patently absurd, inherently improbable, barred by law, or amount to an abuse of process. A charge cannot be quashed merely because the dispute has civil overtones if the allegations and supporting materials disclose criminality. Here, the suicide note and related materials, if accepted at face value, disclosed circumstances capable of amounting to abetment, and the High Court had gone beyond its jurisdiction by undertaking an impermissible appreciation of evidence.

Conclusion: The High Court was not justified in quashing the charge under Section 306 of the Indian Penal Code, 1860. The charge was liable to be restored and the trial to proceed.

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