Inherent powers cannot quash a prima facie criminal and PMLA case where disputed facts and evidence require trial.

Section 482 CrPC relief was declined because the allegations disclosed a prima facie case and the issues turned on disputed facts and evidence. The subsequent committee report on damages did not extinguish the criminal case or the PMLA complaint, as its relevance and admissibility were matters for trial. Proceedings against the women accused were also not quashed, since the record prima facie showed their connection with the quarrying concern during the relevant period. Delay, alleged mala fides, and challenges to witness statements did not justify quashing, and the PMLA prosecution remained maintainable despite disputes over the predicate offences.

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Issues: (i) whether the subsequent committee report dated 31.03.2021 furnished a ground to quash the criminal proceedings and PMLA complaint; (ii) whether the proceedings against the women accused could be quashed for want of incriminating material; (iii) whether delay in registration of the criminal case, alleged mala fides, and the plea that witness statements were merely stereotyped versions justified quashing; and (iv) whether the PMLA prosecution could be terminated on the basis that the predicate offences were disputed or not finally established.

Issue (i): whether the subsequent committee report dated 31.03.2021 furnished a ground to quash the criminal proceedings and PMLA complaint;

Analysis: The report was prepared for the limited purpose of assessing damages in recovery proceedings and did not determine criminal liability. The report was disputed, not accepted by the Government, and its evidentiary value, correctness, and admissibility were matters for trial. The existence or non-existence of civil recovery proceedings, or the acceptance of any committee report, would not by itself extinguish the criminal prosecution arising from the alleged illegal quarrying and laundering of proceeds.

Conclusion: The report dated 31.03.2021 did not justify quashing of the proceedings.

Issue (ii): whether the proceedings against the women accused could be quashed for want of incriminating material;

Analysis: The materials on record prima facie disclosed that the women accused were partners in the quarrying concern during the relevant period and were connected with the alleged illegal mining operations. Their later retirement from the firm did not erase possible liability for acts committed during the period of active association. The question of their exact role and participation required appreciation of evidence at trial.

Conclusion: The proceedings against the women accused were not liable to be quashed on that ground.

Issue (iii): whether delay in registration of the criminal case, alleged mala fides, and the plea that witness statements were merely stereotyped versions justified quashing;

Analysis: The allegations related to continuing and large-scale economic offences involving illegal quarrying, damage to public property, and alleged laundering of proceeds. In such a setting, delay in registration was not by itself fatal. Allegations of mala fides and the contention based on similarity of statements under Section 161 CrPC raised disputed factual questions and could not be decided in proceedings under Section 482 CrPC. The Court was not required to conduct a mini trial at the quash stage.

Conclusion: These grounds did not warrant interference.

Issue (iv): whether the PMLA prosecution could be terminated on the basis that the predicate offences were disputed or not finally established;

Analysis: The offence under the Prevention of Money Laundering Act, 2002 is distinct and independent. Once the complaint and accompanying materials disclosed prima facie proceeds of crime and laundering activity, the Court could not quash the prosecution merely because the accused disputed the predicate offences. The burden and evidentiary issues under the Act were matters for trial, and the existence of multiple surviving scheduled offences meant that the substratum of the PMLA case remained intact.

Conclusion: The PMLA proceedings were maintainable and not liable to be quashed.

Final Conclusion: The Court declined to exercise inherent jurisdiction to interfere with the criminal revisions and quash petitions, holding that the materials disclosed a prima facie case fit for trial and that all disputed factual and evidentiary issues must be resolved by the trial court.

Ratio Decidendi: Inherent jurisdiction under Section 482 CrPC cannot be used to quash criminal proceedings where the allegations disclose a prima facie case, the issues turn on disputed facts and evidence, and the PMLA prosecution is founded on surviving scheduled offences and alleged proceeds of crime.

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