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Issues: Whether a petition under Section 482 of the Code of Criminal Procedure, 1973 could be used to quash a complaint under Sections 138 and 142 of the Negotiable Instruments Act, 1881 where the defence rested on disputed factual questions about payment and appropriation of the cheque amount.
Analysis: The petition turned on rival factual assertions regarding the timing and purpose of the NEFT payment and whether it was made towards the cheque liability. The record showed that the parties' versions were materially disputed and the petitioner's email did not conclusively support the claim that the payment was towards the cheque amount. In such a situation, the scope of inherent jurisdiction does not extend to resolving contested facts or assessing the defence on merits. A complaint can be quashed only where it does not disclose an offence or is otherwise frivolous, vexatious, or oppressive; questions requiring evidence must be left to trial.
Conclusion: The petition for quashing was not maintainable on the disputed factual matrix and was liable to be rejected.
Ratio Decidendi: Inherent powers under Section 482 of the Code of Criminal Procedure, 1973 cannot be exercised to decide disputed questions of fact in a complaint under Section 138 of the Negotiable Instruments Act, 1881, and such matters must ordinarily be left for trial unless the complaint fails to disclose an offence or is otherwise frivolous or vexatious.