Quashing criminal proceedings requires clear absurdity or abuse of process; mere delay will not end the prosecution.

Quashing of criminal proceedings in writ jurisdiction is an exceptional remedy and should not be ordered on incomplete materials unless the complaint is clearly barred, patently absurd, inherently improbable, or the abuse of process is established with sufficient certainty. Mere adverse features in the complaint do not justify termination while evidence is still unfolding. Delay in the proceeding also does not by itself warrant quashing; the court must assess responsibility for the delay and whether prejudice amounting to denial of speedy trial under Article 21 is shown on the record. Where delay is substantially linked to the accused's objections or interlocutory steps, continuation of the prosecution is ordinarily permitted.

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Issues: (i) whether the criminal proceeding could be quashed in writ jurisdiction at the stage when evidence was incomplete, on the grounds of alleged absurdity, inherent improbability and abuse of process; (ii) whether the delay in the proceeding justified quashing on the ground of denial of speedy trial and fair trial.

Issue (i): whether the criminal proceeding could be quashed in writ jurisdiction at the stage when evidence was incomplete, on the grounds of alleged absurdity, inherent improbability and abuse of process.

Analysis: The governing principle is that quashing of criminal proceedings is an exceptional power and ordinarily the criminal court must be left to complete the trial when the evidence is still unfolding. The materials then available did not justify a final finding that the complaint was patently absurd or inherently improbable. The earlier remand order had already indicated that the accused could raise available objections at the appropriate stage, and the writ court should not have treated incomplete materials as conclusive. The existence of some adverse or doubtful features in the complaint did not, at that stage, warrant termination of the prosecution.

Conclusion: The proceeding should not have been quashed on this ground; the finding is against the respondent.

Issue (ii): whether the delay in the proceeding justified quashing on the ground of denial of speedy trial and fair trial.

Analysis: Speedy trial is part of fair procedure under Article 21, but the court must examine who was responsible for the delay and whether the prejudice is established on the record. On the materials then before the court, the delay was not shown to rest mainly on the complainant; the proceedings had been protracted substantially by objections and interlocutory steps taken by the accused. The stage had not been reached where a final constitutional inference could be drawn that continuation of the prosecution would be an abuse or a denial of justice. Section 468 of the Code of Criminal Procedure, 1973 did not justify quashing in the manner adopted, and the proper course was to allow the trial to proceed.

Conclusion: The delay did not justify quashing the prosecution at that stage; the finding is against the respondent.

Final Conclusion: The writ order quashing the criminal proceeding was unsustainable, and the criminal trial was directed to go on in accordance with law.

Ratio Decidendi: A criminal proceeding should not be quashed in writ jurisdiction on incomplete materials unless the case is clearly barred, patently absurd, or the abuse of process is established with sufficient certainty; mere delay does not justify quashing unless the court can fairly conclude, on the available record, that the constitutional right to speedy trial has been infringed in a manner warranting termination of the prosecution.

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