Inherent power to quash FIR at threshold is limited; police must investigate cognizable complaints disclosed by a University.

Section 482 CrPC is to be exercised sparingly and in rare cases; a High Court should not quash an FIR at the threshold before investigation has begun, especially where no proceeding is pending and the affected party has not been heard. An order quashing the FIR and making consequential observations affecting the University's disciplinary authority was therefore unsustainable. A complaint by the University could not be ignored merely because the alleged offenders were outsiders or because its internal rules did not bind them. If the complaint disclosed a cognizable offence, the police were bound to register and investigate it in accordance with law.

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Issues: (i) Whether the High Court could invoke its inherent powers to quash a First Information Report before investigation and without hearing the University; (ii) whether the police were obliged to record and investigate the University's complaints where a cognizable offence was disclosed.

Issue (i): Whether the High Court could invoke its inherent powers to quash a First Information Report before investigation and without hearing the University.

Analysis: The inherent power under Section 482 of the Code of Criminal Procedure, 1973 is to be exercised sparingly, with circumspection, and only in rare cases. Where the police had not even commenced investigation and no proceeding was pending in any court, the High Court had no proper basis to quash the First Information Report. The High Court also made observations affecting the University's disciplinary authority without giving it a hearing.

Conclusion: The High Court's order quashing the First Information Report and making the consequential observations was unsustainable.

Issue (ii): Whether the police were obliged to record and investigate the University's complaints where a cognizable offence was disclosed.

Analysis: A complaint made by the University could not be ignored merely because the alleged offenders were outsiders or because the University's rules were said not to bind them. If the complaint disclosed a cognizable offence, the police were bound to act in accordance with law and could not refuse to register or investigate it.

Conclusion: The police were under a duty to record and investigate such complaints when the law so required.

Final Conclusion: The appeal succeeded, the High Court's judgment was set aside, and the police were reminded of their legal obligation to deal with cognizable complaints in accordance with law.

Ratio Decidendi: The inherent power to quash criminal proceedings must be exercised sparingly and cannot be used to terminate a complaint at the threshold before investigation, while the police remain bound to investigate a cognizable offence disclosed in a complaint.

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