Inherent power to quash criminal proceedings applied where the complaint lacked a prima facie foundation and record supported the accused's version.

Criminal proceedings may be quashed in the exercise of inherent jurisdiction where the allegations, even if taken at face value, do not disclose an offence or the prosecution is otherwise manifestly unsupported by the record, consistent with the Bhajan Lal categories and later cautionary principles. Applying that standard, the Court noted that the marriage certificate and related documents supported the appellant's version, while the complaint material did not provide factual basis for allegations of forgery or the other charged offences. The prosecution was found to lack a prima facie foundation and to be oppressive on the available record, so the proceedings were liable to be quashed.

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Issues: Whether the criminal proceedings arising from the FIR disclosed any prima facie offence and warranted quashing under the inherent jurisdiction.

Analysis: The settled principles governing exercise of inherent power to quash criminal proceedings were applied, including the categories illustratively indicated in Bhajan Lal and the caution reiterated in later decisions that quashing is justified where the allegations, even if accepted at face value, do not constitute an offence or where the proceeding is manifestly attended with mala fides. On the record, the marriage certificate and related documents were found to support the appellant's version, while the complaint material did not furnish factual support for the allegations of forgery or other offences. The material disclosed no foundation for the charge-sheeted offences and the continuation of the prosecution was assessed as oppressive and unsupported by the available record.

Conclusion: The criminal proceedings were liable to be quashed; the appeal succeeded in favour of the appellant.

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