Quashing of criminal proceedings under inherent powers was refused where investigation showed disputed facts and prima facie involvement.

Inherent jurisdiction under Section 482 CrPC cannot be used to quash criminal proceedings where the allegations disclose serious triable issues and disputed questions of fact requiring investigation or trial. Here, the alleged manipulation of RFID e-seals for export cargo, including disabling tamper alerts and allowing faulty seals to pass customs checks, was supported by investigation material and statements indicating board-level knowledge. Because the record raised serious factual disputes and prima facie involvement, the Court held that evidence could not be weighed at the quashing stage and declined to quash the proceedings.

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Issues: Whether the criminal proceedings arising from the FIR could be quashed in exercise of inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973 in the face of serious allegations, admissions in the investigation, and disputed questions of fact.

Analysis: The allegations concerned alleged manipulation of RFID e-seals used for export cargo, including switching off tamper alerts and permitting allegedly faulty seals to pass customs checks. The material recorded during investigation, including the petitioner's statements, indicated that the tamper alert system was intentionally switched off by the company and that the decision was known at board level. The controversy thus involved serious factual disputes and admissions that could not be resolved in a proceeding for quashing. The Court applied the settled principle that inherent powers are to be exercised sparingly and that appreciation of evidence is impermissible at the quashing stage, especially where the allegations disclose triable issues affecting public revenue and national security.

Conclusion: The criminal proceedings were not liable to be quashed, and the petition was rejected against the petitioners.

Ratio Decidendi: Inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973 cannot be used to quash criminal proceedings where the allegations disclose serious triable issues and disputed questions of fact requiring investigation or trial, particularly when the material collected during investigation indicates prima facie involvement.

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