Inherent power to quash criminal proceedings applies where a complaint is vague, mala fide, and an abuse of process.

Criminal proceedings may be quashed under the High Court's inherent jurisdiction where the complaint, read as a whole and in the surrounding circumstances, is manifestly mala fide, vague, vexatious, or an abuse of the process of court. Applying that standard, the complaint here contained only vague assertions, omitted any date for the alleged demand, and appeared to have been filed as a counterblast to earlier action against the complainant. The selective omission to proceed against one of the originally named persons further supported the inference of mala fides. The proceedings were therefore held liable to be quashed under Section 482 of the Code of Criminal Procedure, 1973.

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Issues: Whether the criminal proceedings deserved to be quashed under Section 482 of the Code of Criminal Procedure, 1973 on the ground that the complaint was mala fide, vague, and an abuse of the process of court.

Analysis: The power under Section 482 is exceptional and must be exercised sparingly to prevent abuse of process or secure the ends of justice. Quashing is justified where the complaint, read as a whole, does not disclose an offence, is frivolous or vexatious, or where the proceeding is manifestly attended with mala fides. Applying those principles, the complaint was found to rest on vague assertions, with no date given for the alleged demand, and the surrounding circumstances showed that the complaint was brought as a counterblast to prior action taken against the complainant. The selective omission to proceed against one of the originally named persons further supported the inference of mala fides.

Conclusion: The proceedings constituted abuse of the process of court and were liable to be quashed under Section 482 of the Code of Criminal Procedure, 1973. The appeal was allowed.

Ratio Decidendi: Criminal proceedings may be quashed in exercise of inherent jurisdiction where the complaint, on its face and in the surrounding circumstances, is manifestly mala fide, vexatious, or an abuse of the process of court.

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