Prior exoneration on merits and vague allegations led to quashing of criminal harassment and stalking proceedings.

Prior exoneration on merits in departmental and Internal Complaints Committee proceedings, coupled with a later FIR containing vague and omnibus allegations, justified quashing of the criminal case under inherent powers. The HC held that when identical facts had already been found unproved and the witnesses did not support any specific incident of harassment or stalking, continuation of prosecution would amount to abuse of process. The complaint also failed to disclose the ingredients of the invoked offences, so the FIR, charge-sheet and consequent criminal proceedings were set aside.

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Issues: Whether the FIR, charge-sheet and criminal case arising from allegations under Sections 354-A and 354-D of the Indian Penal Code, 1860 were liable to be quashed in exercise of inherent powers under Section 482 of the Code of Criminal Procedure, 1973, where prior departmental and ICC enquiries had exonerated the applicant on merits and the complaint contained only vague and omnibus allegations.

Analysis: The allegations in the FIR were tested against the earlier enquiry findings. Both the departmental committee and the Internal Complaints Committee had found that the allegations against the applicant were not proved and had exonerated him. The later criminal complaint was found to arise after the applicant had earlier complained about the complainant's conduct, and the witnesses did not support any specific incident of harassment or stalking. The Court applied the principle that where exoneration in disciplinary or adjudicatory proceedings is on merits on identical facts, and the criminal allegations are unsupported by specific material, continuation of prosecution amounts to abuse of process. The allegations were also held to be general, vague and insufficient to disclose the ingredients of the offences invoked.

Conclusion: The criminal proceedings were quashed as the case fell within the parameters for exercise of inherent jurisdiction and the allegations did not prima facie make out the offences alleged.

Final Conclusion: The applicant was entitled to relief, and the FIR, charge-sheet and consequent criminal case were set aside.

Ratio Decidendi: Where a person is exonerated on merits in prior proceedings on the same facts, and the subsequent criminal complaint contains only vague, omnibus and unsupported allegations, continuation of prosecution may be quashed as an abuse of process.

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