Inherent power to quash criminal proceedings must be used sparingly where coal transport and tax evasion allegations remain unproven.

Allegations of illegal coal transportation in multiple trucks, with possible theft and tax evasion affecting public revenue, were found insufficiently disproved at the quashing stage. Applying the settled rule that inherent power under Section 482 CrPC must be used sparingly, with circumspection, and only in rare cases to prevent abuse of process or secure the ends of justice, the HC held that the petitioner's documents did not satisfactorily show that no offence was made out. As no mala fide or improper motive by the investigating agency was established, the Court refused to undertake a detailed inquiry into the truth of the allegations and declined to quash the FIR and criminal proceeding.

---

---

Issues: Whether the FIR and criminal proceeding arising from allegations of illegal coal transportation and evasion of tax were liable to be quashed in exercise of inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973.

Analysis: The allegations disclosed transportation of coal in several trucks without acceptable supporting material and raised issues of possible theft and tax evasion affecting the public revenue. The Court applied the settled principle that the inherent power to quash a criminal proceeding must be exercised sparingly, with circumspection, and only in rare cases to prevent abuse of process or secure the ends of justice. On the materials placed, the petitioner's documents did not satisfactorily substantiate the claim that no offence was made out, and no mala fide or improper motive on the part of the investigating agency was found. In such circumstances, the Court declined to embark upon a detailed inquiry into the truthfulness of the allegations at the quashing stage.

Conclusion: The prayer for quashing was rejected and the criminal petition was not interfered with under Section 482 of the Code of Criminal Procedure, 1973.

---