Inherent power to quash criminal proceedings may be used where a complaint shows no prosecutable case or clear abuse of process.

The inherent power under Section 482 CrPC is to be exercised sparingly to prevent abuse of process and secure the ends of justice, but quashing is warranted where the complaint on its face does not disclose a prosecutable case or where the proceedings are manifestly mala fide. Applying those settled principles, the allegations and surrounding circumstances brought the case within the recognised category for interference, and the criminal proceedings were liable to be quashed.

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Issues: Whether the High Court ought to have exercised inherent powers to quash the criminal proceedings on the ground that the complaint disclosed abuse of process and did not justify continuance of prosecution.

Analysis: The inherent power under Section 482 of the Code of Criminal Procedure, 1973 is preserved to give effect to orders under the Code, prevent abuse of the process of court, and secure the ends of justice. It is to be exercised sparingly and with caution, but quashing is justified where the complaint, even on its face, does not disclose a case warranting prosecution or where the proceeding is manifestly attended with mala fides. Applying the settled principles governing quashing, the allegations and surrounding circumstances showed that the prosecution fell within the recognised category of cases in which interference is warranted.

Conclusion: The criminal proceedings were liable to be quashed and the appeal was allowed.

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