Inherent powers under Section 482 CrPC cannot short-circuit a prosecution when FIR material discloses a prima facie offence.

Section 482 CrPC must be exercised sparingly to prevent abuse of process or secure the ends of justice, and it cannot replace a trial by testing the sufficiency or reliability of evidence at the threshold. Where the FIR and accompanying material disclose a prima facie offence, issues of culpability and adequacy of proof must ordinarily be left to investigation and trial. On that basis, the High Court was not justified in quashing the FIR, and the criminal proceedings were permitted to continue.

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Issues: Whether the High Court was justified in quashing the FIR under Section 482 of the Code of Criminal Procedure, 1973 on the ground that the seized materials did not show intended use for manufacturing illicit liquor.

Analysis: The inherent power under Section 482 is to be exercised sparingly and only to prevent abuse of process or secure the ends of justice. It is not a substitute for trial, and the High Court should not evaluate the sufficiency or reliability of the material as if deciding guilt. Where the FIR and the materials collected disclose the possibility of an offence, questions about adequacy of evidence and culpability must ordinarily be left to investigation and trial. The presence of witness statements and seizure of black jaggery and related materials could not be treated as irrelevant at the threshold.

Conclusion: The High Court was not justified in quashing the FIR, and the order quashing the proceedings could not be sustained.

Final Conclusion: The appeals succeeded and the FIR quashing was set aside, leaving the criminal proceedings to continue in accordance with law.

Ratio Decidendi: Inherent powers under Section 482 of the Code of Criminal Procedure, 1973 cannot be used to short-circuit a prosecution where the FIR and accompanying material disclose a prima facie offence and the issue of sufficiency of evidence is for trial.

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