Quashing of criminal proceedings on undisputed passport and immigration records where the accused was outside India on the alleged date.

The Supreme Court held that criminal proceedings could be quashed under inherent powers where undisputed public documents showed the accused was outside India on the date of the alleged incident. The earlier complaint did not name the accused, and the later FIR depended substantially on an that passport and immigration records contradicted. Because those public documents were not disputed, the Court said the High Court could have considered them instead of sending the matter to trial, and continuation of the prosecution would serve no useful purpose. The High Court's order was set aside and the proceeding quashed.

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Issues: Whether the criminal proceeding arising from the FIR ought to be quashed in exercise of inherent powers under Section 482 on the basis of public documents showing that the accused-appellant was outside India on the date of the alleged .

Analysis: The earlier complaint had not named the accused-appellant, while the subsequent FIR rested substantially on an incident said to have occurred on 27.08.2005. Passport and immigration records placed before the Court showed that the accused-appellant was not in India on that date. These documents were public documents, and their correctness was not disputed. In such circumstances, the High Court could have looked into the documents rather than relegating the matter entirely to trial, because the continuation of the prosecution would serve no useful purpose.

Conclusion: The criminal proceeding was liable to be quashed, and the order of the High Court was set aside in favour of the accused-appellant.

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