Inherent power to quash criminal complaints applies where proceedings are retaliatory counterblasts and amount to abuse of process.

Section 482 CrPC permits quashing of criminal proceedings only sparingly, to prevent abuse of process or secure the ends of justice. The recognised grounds include failure to disclose an offence, inherently improbable allegations, and proceedings that are manifestly mala fide or instituted with an ulterior motive. Applying that principle, the complaint and surrounding circumstances showed a retaliatory counterblast following earlier action by the accused, making the prosecution oppressive and not a legitimate criminal proceeding. The proceedings were therefore liable to be quashed as an abuse of process.

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Issues: Whether the criminal complaint proceedings, including the summons and subsequent coercive process, were liable to be quashed under the inherent jurisdiction on the ground that they were instituted as a counterblast and amounted to abuse of the process of court.

Analysis: The inherent power under Section 482 of the Code of Criminal Procedure, 1973 is to be exercised sparingly and only to prevent abuse of process of court or to secure the ends of justice. The recognised categories for quashing include cases where the complaint does not disclose any offence, where the allegations are inherently improbable, or where the criminal proceeding is manifestly attended with mala fides and instituted with an ulterior motive. The complaint and surrounding circumstances showed that the proceedings were initiated after earlier action by the appellants and were retaliatory in nature. On that basis, the continuation of the complaint was found to be oppressive and not a legitimate prosecution.

Conclusion: The proceedings were liable to be quashed, as they were found to be a counterblast and an abuse of the process of law.

Ratio Decidendi: Inherent powers under Section 482 of the Code of Criminal Procedure, 1973 may be invoked to quash criminal proceedings where the complaint, viewed as a whole, discloses mala fides and abuse of process, including retaliatory proceedings instituted as a counterblast.

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