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2026 Supreme(Ori) 439

IN THE HIGH COURT OF ORISSA AT CUTTACK
SANJEEB K.PANIGRAHI, J.
Juli Pradhan – Petitioner
Versus
State of Odisha & Anr. - Opposite Parties
CRLMC No.3193 of 2025
Decided On : 27-02-2026

Advocates Appeared:
For the Petitioner: Mr. Himanshu Sekhar Mishra, Adv.
For the Opposite Parties : Mr. Udit Ranjan Jena, AGA.

The High Court's inherent jurisdiction under Section 482 allows intervention only in exceptional circumstances to prevent abuse of process, emphasizing that allegations must be taken at face value without conducting a mini-trial.

Headnote:(A) Bharatiya Nyaya Sanhita, 2023 - Sections 85, 108 and 3(5) - Quashing of FIR - High Court denied petition for quashing FIR as allegations disclosed commission of offence; scope of inherent jurisdiction outlined - Respondent’s closure of investigation and absence of material against petitioner were not compelling grounds for quashing. (Paras 6, 12, 13)

(B) Criminal Procedure Code - Section 482 - Exercise of inherent jurisdiction by High Court - Not to be exercised lightly; only to prevent abuse of process or secure ends of justice. (Paras 7, 10)

Facts of the case:
The case involves a FIR lodged alleging that the petitioner was responsible for the suicide of her sister-in-law. The petitioner challenged the FIR, claiming it was false and without basis.

Findings of Court:
The Court found no compelling reasons to quash the FIR and held the allegations, taken at face value, did disclose a commission of an offence.

Issues: Primary issues included whether sufficient grounds existed to quash the FIR and if the allegations could be conclusively dismissed at this stage.

Ratio Decidendi: The Court ruled that the materials on record did not satisfy the criteria for quashing the FIR under inherent powers; a preliminary examination of allegations indicated possible commission of an offence.

Result: Petition dismissed.

Table of Content
1. factual background of the case. (Para 1 , 2)
2. arguments presented by the petitioner. (Para 3 , 4)
3. court's reasoning on inherent jurisdiction. (Para 5 , 6 , 7 , 8 , 9 , 10 , 11)
4. final decision and dismissal of the petition. (Para 12 , 13 , 14 , 15)

JUDGMENT :

Sanjeeb K. Panigrahi, J.

1. The petitioner, in the present CRLMC, seeks quashing of the F.I.R. registered in connection with Muniguda P.S. Case No.115 of 2025 corresponding to G.R. Case No.211 of 2025, pending in the Court of the learned J.M.F.C., Muniguda.

I. FACTUAL MATRIX OF THE CASE

2. The brief facts of the case are as follows:

i. The prosecution case, as per the written report lodged on 01.06.2025 at about 8.20 p.m. by one Satish Prasad Tripathy before the Muniguda Police Station, is that his daughter, Atashi Tripathy, had married Samir Kumar Sahu, resident of Bhanjanagar Block, on 31.01.2012. It was stated that Atashi Tripathy was working as a CRC under Muniguda Block. Due to the absence of her husband, she had been staying at her parental home for the preceding ten days.On 01.06.2025 at about 11.00 a.m., she left home to attend a meeting at the Block Office and did not return till about 3.00 p.m. In the meantime, the informant received a telephonic call from his son-in- law informing him that his daughter was in a distressed state and might take an extreme step.The informant, along with his wife, rushed to her house at Gobardhan. On reaching there, they found the door closed from inside. Despite repeated calls, there was no response. They thereafter broke open the back door and entered the house, where they found Atashi Tripathy hanging in her bedroom with a stole tied to the ceiling fan.The informant immediately cut the stole and brought her down and shifted her to the Community Health Centre, Muniguda, where the attending doctor declared her dead. It was further alleged that the informant returned to the house and found a diary on the dressing table containing a note purportedly in the handwriting of the deceased, wherein it was stated that her husband, Samir Kumar Sahu, was responsible for her suicide.

ii. Upon receipt of the written report, Muniguda P.S. Case No. 115 of 2025 was registered for alleged commission of offences under Sections 85, 108 and 3(5) of the Bharatiya Nyaya Sanhita, 2023. The said case corresponds to G.R. Case No. 211 of 2025, which is pending before the Court of the learned J.M.F.C., Muniguda. The petitioner was arrested on 03.06.2025 and remanded to custody.

iii. The petitioner moved an application for bail before the learned Additional District and Sessions Judge, Bissam Cuttack, which was rejected on 13.06.2025.

iv. Thereafter, the petitioner filed BLAPL No. 6329 of 2025 before this Court, and by order dated 10.07.2025, this Court allowed the said bail application subject to certain conditions.

v. The present petition has been filed seeking quashing of the aforesaid F.I.R. and the consequential criminal proceedings arising therefrom.

II. SUBMISSIONS ON BEHALF OF THE PETITIONER

3. Learned counsel for the petitioner made the following submissions in support of his contentions:

i. It was submitted that the petitioner is a young unmarried lady and has been falsely implicated in the present case on account of alleged family disputes involving the informant.

ii. It was contended that the petitioner has no involvement whatsoever in the alleged occurrence and that there is no clinching or cogent material available on record to connect her with the commission of the alleged offences. On such grounds, it was prayed that the F.I.R. and the consequential criminal proceedings be quashed.

iii. It was further submitted that the investigation in the aforesaid case has substantially progressed and no material has surfaced against the petitioner. It was contended that continuation of the criminal proceedings against her would seriously prejudice her future prospects.

iv. It was further submitted that the F.I.R. has been lodged with a mala fide in

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