Discharge stage scrutiny under CrPC is limited to prima facie case; courts cannot demand clinching proof or weigh evidence.

At the discharge stage under Section 239 CrPC, the court must ask only whether the materials disclose a prima facie case or make the charge groundless; it cannot weigh evidence, seek clinching proof, or conduct a trial-like appraisal. Strong suspicion based on the record is sufficient to frame charge, and revisional interference is justified only in rare cases. The Supreme Court held that the High Court exceeded this limited jurisdiction by examining income-tax materials, drawing its own inference on the source of income, and insisting on proof of abetment, so its approach was legally unsustainable and the discharge order could not stand.

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Issues: Whether the High Court was justified in setting aside the order refusing discharge and quashing the charge at the stage of Section 239 of the Code of Criminal Procedure, 1973 by undertaking a detailed appraisal of the materials and seeking clinching proof of abetment.

Analysis: The governing test at the stage of discharge is whether the charge is groundless or whether the materials disclose a prima facie case. The court at that stage does not weigh the sufficiency of evidence, assess documents as if conducting the trial, or determine whether the materials are clinching. Even a strong suspicion founded on the materials is enough to frame charge, and revisional interference with such an order is warranted only in rare cases. The High Court went beyond this limited jurisdiction by examining the respondent's income-tax materials, drawing inferences on the source of income, and concluding that no clinching material existed to show abetment.

Conclusion: The High Court's approach was legally unsustainable, and the order discharging the respondent could not be sustained.

Ratio Decidendi: At the stage of discharge or framing of charge, the court must confine itself to whether the materials disclose a prima facie case or render the charge groundless, and it cannot conduct a roving evaluation of evidence or insist on clinching proof.

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