Prima facie standard at charge stage bars detailed evidence review where record shows sufficient material to proceed.

At the stage of framing of charges, the court applies only a prima facie standard and does not conduct a detailed appraisal of evidence or a roving enquiry into the merits. Where the material on record, taken at face value, discloses sufficient grounds to proceed, interference with the charge order is not warranted. On the facts described, allegations that notifications were issued without Cabinet approval and in breach of rules provided adequate material to continue proceedings, so discharge at the threshold was refused and the challenge to the framing of charges failed.

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Issues: Whether the High Court was justified in refusing to interfere with the order framing charges and whether the material on record disclosed a prima facie case for proceeding against the accused.

Analysis: At the stage of framing of charges, the court is required to apply only the prima facie standard. The court is not expected to conduct a meticulous evaluation of evidence or undertake a roving enquiry into the merits as if it were a trial. On the facts placed before it, the Court found that the notifications alleged to have been issued without Cabinet approval and in violation of rules furnished sufficient material to proceed. The Court therefore accepted the High Court's view that the record did not justify discharge at the threshold.

Conclusion: The challenge to the framing of charges failed, and no interference was warranted with the High Court's order.

Ratio Decidendi: At the stage of framing of charges, interference is unwarranted where the material on record, taken at its face value, discloses a prima facie case and does not call for a detailed examination of evidence.

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