Quashing of criminal process where complaint and public records showed the accused had ceased to be a director before the alleged conspiracy.

Where a complaint, read as a whole with undisputed public records, shows that an accused had already ceased to be a director before the alleged conspiratorial acts, no factual basis exists to connect that person with the alleged offence. The High Court may act on the admitted record in its inherent and supervisory jurisdiction and quash the criminal process, because continuation of prosecution in such circumstances would amount to needless harassment and no offence is disclosed against that accused. The complaint's own reference to the person as an ex-director, supported by the Registrar of Companies record, was decisive.

---

---

Issues: Whether the criminal process issued against an ex-director was liable to be quashed under the Court's inherent and supervisory jurisdiction on the ground that the complaint itself showed he had ceased to be a director before the alleged joining of the conspiracy.

Analysis: The complaint was to be read as a whole without addition or subtraction of facts. The undisputed material showed that the petitioner had ceased to be a director of the concerned company before the complaint's own averments placed the company's alleged entry into the conspiracy. The complaint also described him as an ex-director, and the public record of the Registrar of Companies supported that position. On those admitted facts, there was no factual basis to connect him with the alleged conspiratorial acts, and continuation of the prosecution against him would amount to needless harassment. In such a case, the Court could act on the undisputed public record and decline to permit criminal process to continue.

Conclusion: The process issued against the petitioner was liable to be quashed, and the proceedings against him could not be sustained.

Ratio Decidendi: Where the complaint, read on its face along with undisputed public records, shows that an accused had ceased to hold office before the alleged criminal act, the Court may quash the process under its inherent powers because no offence is disclosed against that accused.

---