Inherent jurisdiction cannot be used to test disputed evidence in a Section 138 complaint; quashing was declined.

In a complaint under Section 138 of the Negotiable Instruments Act, the HC reiterated that inherent jurisdiction under Section 482 CrPC is to be exercised sparingly, only to prevent abuse of process or secure the ends of justice. Because the challenge did not cover all material orders and the trial court had already acted on the complaint, Section 200 statements and Section 202 material, the Court held that disputed evidence and factual inconsistencies could not be examined at the quashing stage. As no ground for interference was made out, quashing of the criminal proceedings and related coercive orders was declined.

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Issues: Whether the criminal proceedings arising out of the complaint under Section 138 of the Negotiable Instruments Act could be quashed in exercise of inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973.

Analysis: The application sought quashing of a long-pending complaint case and related coercive orders. The Court noted that the challenge did not encompass all the material orders in the case and that the trial court had already proceeded on the basis of the complaint, the statement under Section 200 of the Code of Criminal Procedure, 1973, and supporting material under Section 202 of the Code of Criminal Procedure, 1973. Reiterating the settled limits of inherent jurisdiction, the Court held that such power is to be used sparingly only to secure the ends of justice or prevent abuse of process, and that it cannot be employed to assess disputed evidence or factual inconsistencies, which are matters for trial.

Conclusion: No ground was made out for quashing the proceedings, and interference under Section 482 of the Code of Criminal Procedure, 1973 was declined.

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