Inherent powers cannot usually quash an FIR at the investigation stage when cognizable offences are prima facie disclosed.

Inherent powers should not ordinarily be used to quash an FIR or halt a police investigation where the allegations, on their face, disclose cognizable offences. Interference at the investigation stage is justified only in rare cases showing malicious or vexatious prosecution, and not on a premature assessment that the allegations are false. On that principle, the High Court was held not justified in stopping the investigation before a full inquiry, and the criminal investigation was permitted to continue in accordance with law.

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Issues: Whether the High Court was justified in exercising inherent powers to quash the FIR and stop the police investigation at the stage of investigation.

Analysis: The challenge concerned the use of inherent jurisdiction to quash an FIR where the allegations, on their face, disclosed cognizable offences. The governing principle applied was that interference with a police investigation is not ordinarily warranted when the FIR makes out a cognizable offence, and such interference is permissible only in rare cases where the prosecution is shown to be malicious or vexatious. The Court found that, without a full investigation, it was not proper to conclude that the allegations were false or that continuation of the investigation would amount to abuse of process.

Conclusion: The High Court was not justified in quashing the FIR and interfering with the investigation; the police investigation was required to continue.

Final Conclusion: The order quashing the FIR was set aside and the criminal investigation was permitted to proceed in accordance with law.

Ratio Decidendi: Inherent powers should not be used to quash an FIR at the investigation stage when the allegations prima facie disclose a cognizable offence, unless the case falls within exceptional circumstances showing malicious or vexatious prosecution.

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