Quashing jurisdiction limits: High Court cannot conduct a mini-trial or weigh evidence while reviewing complaint proceedings.

In exercise of inherent powers under Section 482 CrPC and supervisory jurisdiction under Article 227, the High Court cannot conduct a mini-trial or reassess the probative value of evidence at the quashing stage. Where cognizance has been taken and process issued after examination of witnesses, interference is limited to testing whether the proceedings disclose a legal basis, not weighing sufficiency or credibility of material. By virtually retrying the complaint and evaluating evidence, the High Court exceeded its jurisdiction. The order was unsustainable, and the complaint proceedings were directed to continue from the stage at which they had been interrupted.

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Issues: Whether the High Court, while exercising jurisdiction under Section 482 of the Code of Criminal Procedure, 1973 and Article 227 of the Constitution of India, could undertake a virtual trial and assess the probative value of evidence at the stage of quashing the complaint and the order taking cognizance.

Analysis: The complaint had resulted in cognizance being taken and process being issued after examination of witnesses. At the stage of considering quashing, the High Court went into the sufficiency and probity of the material and effectively reassessed the evidence, which was beyond the limited scope of interference under the relevant jurisdiction. Such an exercise amounted to travelling beyond the permissible limits of supervisory and inherent powers.

Conclusion: The High Court acted in excess of jurisdiction and its order was unsustainable; the complaint proceedings were directed to continue from the stage at which they had been interdicted.

Ratio Decidendi: In proceedings under Section 482 of the Code of Criminal Procedure, 1973 and Article 227 of the Constitution of India, the High Court cannot conduct a mini-trial or evaluate the probative value of evidence at the quashing stage.

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