Quashing of criminal proceedings is exceptional; courts should not assess conviction prospects at the threshold stage.

SC reiterated that criminal proceedings may be quashed only sparingly, where continuation would amount to abuse of process or where the ends of justice require it. At the quashing stage, the court should not minutely assess evidence or predict conviction, except where allegations are patently absurd, legally barred, or fall within recognised quashing categories. The Court distinguished serious criminal allegations from predominantly civil disputes and compromise cases, and found the contemporaneous complaints of police coercion and forced FIR lodging to be prompt and consistent. On that factual basis, the proceedings were liable to be quashed, though not for the reasons adopted by the High Court.

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Issues: Whether the criminal proceedings could be quashed in exercise of inherent and writ jurisdiction on the ground that the complainant had resiled from the complaint and the High Court considered that the prosecution would not end in conviction.

Analysis: The power to quash criminal proceedings is to be exercised sparingly and only where continuation of the prosecution would amount to abuse of process or where the ends of justice so require. The Court reiterated that at the stage of quashing, it is not proper to undertake a meticulous assessment of the evidence or to decide whether the case will ultimately end in conviction, except in cases where the allegations are patently absurd, legally barred, or otherwise fall within recognised categories justifying quashing. The Court distinguished cases involving predominantly civil disputes and compromise from cases involving serious criminal allegations affecting society at large. On the facts, the complainant's and his wife's contemporaneous complaints alleging police coercion, custody, and forced lodging of the FIR were found to be prompt and consistent, making it possible that the allegations were true. The Court therefore held that the complaint could be quashed, though not on the same reasoning adopted by the High Court.

Conclusion: The criminal proceedings were liable to be quashed, and the appeal failed.

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