Inherent criminal jurisdiction cannot quash a premature investigation unless no offence is disclosed or process abuse is clear.

Inherent jurisdiction under Section 482 CrPC must be used sparingly and only in exceptional cases where the allegations, taken at face value, disclose no offence or where intervention is needed to prevent abuse of process. A court should not ordinarily halt a police investigation at a premature stage, and prior departmental inquiries do not bar criminal investigation because they are distinct in object and consequence. The existence of an arbitration clause also does not exclude criminal law where the allegations disclose criminality. The quashing of the preliminary investigation was therefore unjustified, and the investigation was restored to proceed in accordance with law.

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Issues: Whether the High Court was justified in quashing, in exercise of inherent jurisdiction, a preliminary police investigation before registration of an FIR on the ground that earlier departmental inquiries had been held and an arbitration clause existed.

Analysis: The scope of inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973 is wide but must be exercised sparingly, cautiously and only in exceptional cases where the allegations, taken at face value, do not disclose any offence or where interference is necessary to prevent abuse of process. A court should ordinarily not obstruct investigation at a premature stage unless a case of gross abuse is made out. The departmental inquiries were distinct from police investigation in nature, object and consequence, and the earlier inquiries had not exonerated the respondent. The existence of an arbitration agreement did not exclude criminal law where the allegations disclosed criminality. The High Court's interference was therefore unsustainable.

Conclusion: The quashing of the preliminary investigation was unjustified and the investigation could not be interfered with at the threshold.

Final Conclusion: The appeal succeeded and the investigation was restored to proceed in accordance with law.

Ratio Decidendi: Inherent power under Section 482 of the Code cannot be used to quash a premature investigation unless the case falls within exceptional categories showing no offence or clear abuse of process; a civil or arbitral remedy does not bar criminal investigation where criminality is disclosed.

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