Quashing of criminal proceedings after merit-based POSH exoneration where allegations were vague and prosecution was abusive.

Criminal proceedings based on an FIR under Sections 354A and 506 IPC were treated as unsustainable where the same allegations had already been examined by an Internal Complaints Committee under the POSH Act and the petitioners were exonerated on merits. The Court applied the higher criminal standard of proof, noted that the inquiry and prosecution concerned identical issues, and found the complaint to be general and unparticularised. On that basis, it applied Section 482 CrPC principles that quashing is justified where allegations, even if accepted at face value, do not disclose an offence or where continuation of proceedings is oppressive or abusive. The FIR and consequential proceedings were therefore quashed.

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Issues: Whether the criminal proceedings arising from the FIR under Sections 354A and 506 of the Indian Penal Code, 1860 could be quashed after the petitioners were exonerated on merits by the Internal Complaints Committee constituted under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, and whether the allegations disclosed a prima facie case warranting continuation of prosecution.

Analysis: The Internal Complaints Committee was held to have conducted a detailed inquiry on the same allegations and exonerated the petitioners on merits. The Court relied on the principle that criminal prosecution requires proof beyond reasonable doubt, whereas the committee proceedings are based on a lower standard of proof. It was found that the issues in the inquiry and the criminal case were identical, the complaint contained only general and unparticularised allegations, and continuation of prosecution after merit-based exoneration would amount to abuse of process. The Court also applied the principles governing quashing under Section 482 of the Code of Criminal Procedure, 1973, including the category where allegations, even if accepted at face value, do not disclose an offence and where proceedings are mala fide or oppressive.

Conclusion: The Court held that the FIR and all consequential proceedings could not be sustained and were liable to be quashed in favour of the petitioners.

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