Settled excise liability under Sabka Vishwas justified quashing the criminal complaint once prosecution withdrawal was approved.

Where excise liability had been fully settled under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, supported by a no dues-discharge certificate and departmental approval to withdraw prosecution, continuation of the criminal complaint was unwarranted. The High Court held that the mere pendency of a withdrawal application could not justify keeping the prosecution alive once the underlying liability had ceased to survive. In these circumstances, no fruitful purpose would be served by continuing the complaint, and the petitioners were entitled to relief by quashing it.

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Issues: Whether the criminal complaint based on alleged excise liability could be quashed after the liability was remitted under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, the no dues certificate was issued, and approval had been accorded for withdrawal of the prosecution.

Analysis: The liability stood settled under the Scheme and this was supported by the communication on record, the no dues-discharge certificate, and the departmental approval to withdraw the prosecution. In these circumstances, the mere pendency of an application for withdrawal could not justify continuation of the prosecution. Once the underlying liability had ceased to survive, no fruitful purpose would be served by keeping the criminal complaint alive.

Conclusion: The complaint was liable to be quashed and the petitioners were entitled to relief.

Ratio Decidendi: Where the excise liability has been fully settled under the Sabka Vishwas (Legacy Dispute Resolution) Scheme and the competent authority has approved withdrawal of the prosecution, continuation of the criminal complaint is unwarranted and may be quashed.

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