Inherent jurisdiction cannot quash framed charges in a warrant case by relying on affidavits beyond the police record.

In a warrant case, once a police report has been filed, cognizance taken and charges framed, the High Court cannot treat the matter as still being at the FIR stage and quash the proceedings on principles applicable to pre-investigation review. At the discharge or charge-framing stage under Sections 239 and 240 CrPC, consideration is ordinarily confined to the police report and accompanying documents under Section 173 CrPC. Affidavits and other materials outside that record cannot be used to assess the existence of an offence, except in rare and exceptional cases supported by unimpeachable material. The impugned order was set aside and the matter remitted for fresh consideration.

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Issues: (i) Whether the High Court could quash the criminal proceedings under its inherent jurisdiction after the police report had been filed and charges had already been framed. (ii) Whether, at the stage of considering discharge or framing of charge in a warrant case, the High Court could rely on affidavits and materials beyond the police report and accompanying documents.

Issue (i): Whether the High Court could quash the criminal proceedings under its inherent jurisdiction after the police report had been filed and charges had already been framed.

Analysis: Once the police had submitted the charge-sheet, cognizance had been taken, and charges had been framed, the matter was no longer at the stage of examining whether the FIR disclosed an offence or whether investigation should continue. The proper framework was the procedure governing warrant cases, and the High Court could not approach the case as though it were still at the stage of testing the FIR at the threshold.

Conclusion: The High Court was not justified in quashing the proceedings on the basis of principles applicable to an earlier investigative stage.

Issue (ii): Whether, at the stage of considering discharge or framing of charge in a warrant case, the High Court could rely on affidavits and materials beyond the police report and accompanying documents.

Analysis: At the stage of Sections 239 and 240 of the Code of Criminal Procedure, 1973, the Magistrate is to consider the police report and the documents forwarded with it under Section 173 of the Code of Criminal Procedure, 1973, and decide whether the charge is groundless or whether there is ground for presuming commission of an offence. Once charges are framed on a prima facie view, the High Court cannot ordinarily invoke inherent jurisdiction to quash them by evaluating affidavit evidence or by undertaking a detailed assessment of the merits, save in rare and exceptional situations supported by unimpeachable material.

Conclusion: The High Court could not rely on affidavits or materials outside the permissible record to quash the charges.

Final Conclusion: The impugned order was unsustainable and was set aside, and the matter was sent back for fresh consideration in accordance with law.

Ratio Decidendi: In a warrant case, once a charge-sheet has been filed and charges have been framed on the basis of the police report and accompanying documents, quashing under inherent jurisdiction is impermissible except in rare exceptional cases based on unimpeachable material; affidavits cannot be used to determine the existence of an offence at the charge stage.

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