Sterling defence material can justify quashing criminal proceedings when it conclusively undermines the prosecution case and prevents abuse of process.

Sterling, unimpeached defence material can justify quashing criminal proceedings in inherent jurisdiction when it conclusively displaces the prosecution case and trial would amount to abuse of process. Mobile-location and call-detail records, the complainant's admitted marital history, and medical material were treated as capable of acceptance without trial because they were not refuted and undermined the alleged place of occurrence and the factual basis of the accusations. On that footing, the allegations of rape on a false promise of marriage and outraging modesty were found unsustainable, as the relationship was inconsistent with the claim of inducement by marriage promise and the objective evidence did not support the prosecution version.

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Issues: (i) Whether criminal proceedings were liable to be quashed under the inherent jurisdiction on the basis of unimpeached defence material showing that the accusations could not result in conviction; (ii) Whether the allegations of rape on a false promise of marriage and of outraging modesty were sustainable on the facts and evidence.

Issue (i): Whether criminal proceedings were liable to be quashed under the inherent jurisdiction on the basis of unimpeached defence material showing that the accusations could not result in conviction.

Analysis: The material relied upon by the accused consisted of mobile phone location and call details, the prosecutrix's own admitted marital history, the medical reports, and the charge-sheet itself. These materials were not refuted and were of such character that they could be accepted without trial. The governing test is whether the defence material is sound, reasonable, indubitable, and sufficient to rule out the prosecution version, thereby preventing abuse of process and securing the ends of justice. On that standard, the materials established that the parties were not at the alleged place of occurrence, that the complainant had been married during the relevant period, and that the prosecution case lacked scientific corroboration.

Conclusion: The proceedings were liable to be quashed in exercise of inherent powers.

Issue (ii): Whether the allegations of rape on a false promise of marriage and of outraging modesty were sustainable on the facts and evidence.

Analysis: The claim that physical relations were induced on an assurance of marriage stood contradicted by the complainant's subsisting valid marriage during the relevant dates. The admitted relationship, even if assumed, was consensual and could not support a charge of rape on the asserted basis. The allegation of outraging modesty was also discredited by the objective call-detail evidence, which placed both parties away from the alleged scene of occurrence, and by the medical material which did not support the allegation of poisoning or other supporting circumstances. In the absence of credible corroboration, the accusations were incapable of being sustained.

Conclusion: The allegations were not sustainable and could not lead to conviction.

Final Conclusion: The criminal proceedings arising from the FIR, the charge-sheet, and the framing of charges were unsustainable and were quashed.

Ratio Decidendi: Where unimpeached, sterling defence material conclusively displaces the factual foundation of the prosecution case and shows that continuation of the trial would be an abuse of process, the High Court should exercise its inherent power to quash the proceedings.

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