Quashing of FIR for VAT contravention follows prior penalty and absence of statutory basis for criminal registration.

An FIR alleging contravention of the Punjab Value Added Tax Act, 2005 was challenged under the High Court's inherent power to quash criminal proceedings. The petitioner had already been penalised under the Act and paid the penalty, and the State could not dispute that the Act did not provide for registration of an FIR on those allegations. On that basis, continuation of the criminal proceedings was held unwarranted, and the FIR with all consequential proceedings was quashed against the petitioner.

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Issues: Whether the FIR and consequential criminal proceedings were liable to be quashed in exercise of inherent powers under Section 482 of the Code of Criminal Procedure, 1973.

Analysis: The FIR arose from allegations that the petitioner was bringing goods in contravention of the Punjab Value Added Tax Act, 2005. The petitioner had already been penalised under that Act and had paid the penalty imposed, and the State was unable to dispute the legal position that the Act did not provide for registration of an FIR on those allegations. In these circumstances, continuation of the criminal proceedings was unwarranted.

Conclusion: The FIR and all consequential proceedings were quashed qua the petitioner.

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