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Issues: Whether the High Court was justified in quashing criminal proceedings and FIRs by invoking inherent jurisdiction during pendency of investigation or after filing of charge sheet, and whether such power could be used to evaluate the merits of the accusations at that stage.
Analysis: The inherent power preserved by Section 482 of the Code of Criminal Procedure, 1973 is to be exercised sparingly, carefully and with caution, only to give effect to orders under the Code, to prevent abuse of process of court, or to secure the ends of justice. It is not a power of appeal or revision, and the High Court should not ordinarily undertake a detailed assessment of evidence, reliability of material, or probable defence while the investigation is incomplete or the case is not fit for trial-level appreciation. Quashing is justified only where the allegations, taken at face value, do not disclose any offence, there is a legal bar to the proceedings, or the case squarely falls within recognised categories warranting interference. Mere allegations of mala fides are not by themselves a sufficient ground to short-circuit a prosecution.
Conclusion: The High Court was not justified in quashing the investigation and proceedings; the impugned orders were set aside and the criminal matters were allowed to continue in accordance with law.
Final Conclusion: The proceedings were restored, the quashing orders were annulled, and the investigation was directed to proceed and be completed within the stipulated time, with the respondents required to cooperate.
Ratio Decidendi: The inherent power under Section 482 of the Code of Criminal Procedure, 1973 cannot be used to stifle a legitimate prosecution or to assess disputed evidence at the investigation stage, and interference is warranted only in the narrow categories where no offence is disclosed, a legal bar exists, or the proceeding is manifestly abusive.