Inherent power under Section 482 CrPC applies sparingly; mere allegations of mala fides do not justify quashing criminal proceedings.

Section 482 CrPC confers an exceptional inherent power to be used sparingly and with caution to prevent abuse of process or secure the ends of justice. Quashing is justified only where no offence is disclosed, a legal bar exists, or the proceedings are manifestly mala fide; a bare allegation of mala fides or the presence of collateral disputes is not enough to halt a prosecution before trial testing of the material. On that basis, the High Court's order quashing the criminal proceedings was unsustainable and was set aside.

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Issues: Whether the High Court was justified in quashing the criminal proceedings in exercise of inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973 on the ground of mala fides.

Analysis: Inherent power under Section 482 of the Code of Criminal Procedure, 1973 is an exceptional power to be exercised sparingly, carefully and with caution to prevent abuse of process of court or to secure the ends of justice. Quashing is warranted only in the recognised categories where no offence is disclosed, there is a legal bar, or the proceedings are manifestly attended with mala fide. The mere allegation of mala fides or the existence of collateral disputes does not by itself justify stifling a legitimate prosecution, particularly when the material has not been fully tested at trial.

Conclusion: The High Court was not justified in quashing the proceedings; the impugned order was unsustainable and liable to be set aside.

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