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Issues: Whether the High Court was justified in quashing the criminal proceedings and chargesheet against the accused by exercising inherent powers under Section 482 of the Code of Criminal Procedure, 1973.
Analysis: The allegations disclosed a serious financial irregularity involving large payments said to have been made towards GST liability and allegedly misappropriated. The Court reiterated that inherent jurisdiction is to be exercised sparingly and that quashing is warranted only where the case falls within the recognised categories governing such power. At the stage of quashing, the Court does not undertake a mini-trial or test the truthfulness of the accusations. On the material available, the respondent's own statement contained material broadly consistent with the co-accused's version, and the record was not such as to justify termination of the prosecution at the threshold.
Conclusion: The High Court was not justified in quashing the proceedings. The appeal was allowed and the criminal proceedings were restored for trial.
Ratio Decidendi: In proceedings under Section 482 of the Code of Criminal Procedure, 1973, criminal prosecution should not be quashed where the complaint and accompanying material disclose a prima facie case and the allegations require trial for proper adjudication.