Inherent jurisdiction cannot decide disputed facts where a complaint discloses offence ingredients and trial must assess the defence.

Proceedings under Section 482 CrPC challenging a complaint under the Negotiable Instruments Act were not fit for quashing because the complaint disclosed the essential statutory ingredients of the offence. The court held that inherent jurisdiction cannot be used to assess disputed facts, test the truth of the defence, or weigh evidentiary sufficiency at the pre-trial stage. Where cognizance has been validly taken on a prima facie complaint, the proper course is for the defence and merits to be examined at trial. The criminal proceedings were allowed to continue.

---

---

Issues: Whether the proceedings in the complaint case arising from alleged offences under the Negotiable Instruments Act, 1881 deserved to be quashed in exercise of inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973.

Analysis: The complaint contained allegations attracting the statutory ingredients of the offences and the challenge raised by the petitioner required an assessment of disputed facts and the evidentiary value of the defence. In proceedings under Section 482 of the Code of Criminal Procedure, 1973, the Court cannot embark upon an enquiry into the truth or falsity of the evidence or decide disputed questions that are meant for trial. The proper course is to test the defence and the merits after evidence is led before the trial court, particularly where cognizance has already been taken on a complaint disclosing the essential ingredients of the offence.

Conclusion: The request to quash the criminal proceedings was rejected and the complaint was allowed to proceed to trial.

Ratio Decidendi: The inherent power under Section 482 of the Code of Criminal Procedure, 1973 cannot be used to evaluate disputed facts or the sufficiency of evidence where the complaint discloses the ingredients of the alleged offence and cognizance has been validly taken.

---