Inherent jurisdiction cannot stop an ongoing investigation or unsettle accepted bail conditions without exceptional legal grounds.

Inherent jurisdiction under section 561-A of the Code of Criminal Procedure cannot ordinarily be used to quash criminal proceedings or interrupt an ongoing investigation at a pre-final report stage, absent a clear legal impediment or other exceptional ground; the High Court was therefore justified in declining interference. The Court also held that reasonable bail conditions, including surrender of passport and a bar on leaving India, were valid where imposed to address absconding risk and accepted by the accused when securing release, so they could not later be reopened under section 561-A. The appeal accordingly failed.

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Issues: (i) Whether the High Court should exercise inherent jurisdiction to quash criminal proceedings or interfere with an ongoing investigation at the stage when the case was still under investigation. (ii) Whether the conditions imposed for bail, including surrender of passport and restriction on leaving India, could be interfered with under inherent jurisdiction.

Issue (i): Whether the High Court should exercise inherent jurisdiction to quash criminal proceedings or interfere with an ongoing investigation at the stage when the case was still under investigation.

Analysis: The proceedings arose from cognisable offences and the investigation had not culminated in a final report. The Court held that inherent powers under section 561-A of the Code of Criminal Procedure are to be exercised sparingly, and ordinarily do not justify interference with investigation or quashing proceedings unless there is a clear legal impediment, lack of legal evidence, or other exceptional ground. Questions such as the necessity of sanction or certificate could be raised at the appropriate stage if they in fact became relevant.

Conclusion: The High Court was justified in refusing to quash the proceedings, and interference with the investigation was not warranted.

Issue (ii): Whether the conditions imposed for bail, including surrender of passport and restriction on leaving India, could be interfered with under inherent jurisdiction.

Analysis: The Court held that sections 496, 497 and 498 of the Code of Criminal Procedure do not exhaust the court's power to impose reasonable terms and conditions while granting bail. Given the apprehension that the accused might abscond, the requirement to surrender the passport and not leave India formed part of the bail arrangement and had been accepted when the appellant sought and obtained the modified bail order. The appellant could not, after complying with the order and securing release, seek revision of those conditions under section 561-A.

Conclusion: The conditions attached to bail were valid and did not call for interference or modification.

Final Conclusion: The appeal failed because no ground was made out for the exercise of inherent powers to quash the proceedings or disturb the bail conditions imposed by the High Court.

Ratio Decidendi: Inherent jurisdiction under section 561-A of the Code of Criminal Procedure cannot ordinarily be used to halt an ongoing criminal investigation or to revise reasonable bail conditions accepted by the accused, particularly where the challenge is premature and no exceptional legal impediment is shown.

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