Quashing under Section 482 CrPC is limited to prima facie scrutiny; prosecution material here justified trial.

At the stage of quashing under Section 482 CrPC, the Court must only consider whether the allegations, taken at face value, disclose a cognizable offence or prima facie case; it cannot test the prosecution evidence or conduct a mini-trial. On the allegations of abuse of official position, criminal conspiracy and wrongful allotment of public plots at throwaway prices, the investigative material and charge-sheet were sufficient to require the accused to face trial, so quashing was unsustainable and the criminal proceedings were restored.

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Issues: Whether the High Court was justified in quashing the criminal proceedings under Section 482 of the Code of Criminal Procedure, 1973 against the accused alleged to have participated in an arbitrary allotment of public plots in favour of relatives and family members.

Analysis: The allegations disclosed a prima facie case of abuse of official position, criminal conspiracy, and wrongful allotment of public property at throwaway prices causing loss to the public exchequer. The power under Section 482 of the Code of Criminal Procedure, 1973 is to be exercised sparingly and only in exceptional cases; it cannot be used to test the reliability of the prosecution case or to conduct a mini-trial. The material collected during investigation and the filing of charge-sheet were sufficient to require the accused to face trial, and the case did not fall within the recognised categories warranting quashing.

Conclusion: The quashing order was unsustainable and the criminal proceedings were restored against the accused respondents.

Ratio Decidendi: At the stage of quashing, the Court must only see whether the allegations, taken at face value, disclose a cognizable offence or a prima facie case; it cannot assess evidence in detail or undertake a mini-trial where the prosecution material warrants trial.

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