Limits on quashing criminal proceedings: courts should not decide disputed facts or stop investigation at the threshold.

The Supreme Court reiterated that the power to quash criminal proceedings under Article 226 and Section 482 CrPC must be used sparingly, and that courts at the threshold cannot assess evidence in detail, test credibility, or decide disputed facts such as age or consent. Where the FIR and statements disclose cognizable offences, investigation should ordinarily proceed, and the process should not be stopped by premature factual findings. The High Court also acted beyond jurisdiction in making adverse observations on the complainant's character and in treating the material as insufficient for rape without allowing investigation. The quashing order was set aside and investigation was directed to continue in accordance with law.

---

---

Issues: Whether the High Court was justified in quashing the first information report and the criminal investigation at the threshold on the basis of an appreciation of the victim's statements and by recording findings on age, consent and character.

Analysis: The extraordinary power to quash criminal proceedings under Article 226 of the Constitution of India and Section 482 of the Code of Criminal Procedure, 1973 is to be exercised sparingly and with circumspection, and the Court at that stage cannot embark upon a meticulous examination of evidence, test the reliability of allegations, or weigh competing versions. Where the FIR and statements disclose allegations attracting cognizable offences under the Penal Code, investigation should ordinarily be permitted to continue, and the Court should not short-circuit the process by drawing factual inferences on disputed matters such as age or consent. The High Court also exceeded its jurisdiction in making adverse comments on the character of the complainant and in treating the material as insufficient for rape without permitting investigation to take its course.

Conclusion: The High Court's order quashing the FIR and investigation was set aside and the investigation was directed to proceed in accordance with law.

---