The High Court should not exercise its inherent powers under Section 482 CrPC to quash criminal proceedings or conduct a mini-trial to verify the truthfulness or reliability of allegations once a charge-sheet has been filed; such matters must be left to the Trial Court.

The petitioners have filed the present petition for quashing of FIR No. 94 of 2020, dated 03.07.2020, registered for the commission of offences punishable under Sections 341, 323, 325, 506, 147 and 149 of the Indian Penal Code (IPC) at Police Station Rampur Bushehar, District Shimla, H.P. and the proceedings arising out of the said F.I.R.

Briefly stated, the facts giving rise to the present petition are that the informant Amitabh Kapur received a call from the mobile No. xxxxxxx425 that his presence was required at the Police Station. He went to the Police Station, where Prem Nath Sharma, Deepak Sharma, son of Prem Nath, Sonu Bhaluni and 7-8 persons attacked him. The police registered the F.I.R and investigated the matter. The police checked the CCTV footage and identified Ankit Sharma, Varinder Bhaluni, Naveen Bhaluni, Kirti Sharma, Poonam Sharma and Meenu Sharma as the assailants. The victim suffered simple and grievous injuries in the incident. The police recorded the statements of the witnesses and filed the charge sheet before the Court.

Being aggrieved by the registration of the F.I.R. and consequential proceedings, the petitioners have filed the present petition asserting that the police had not found any material against the petitioners. They had not caused any injury to the victim. The petitioners were falsely implicated due to a family dispute. No offences punishable under Sections 147 and 149 of the IPC are made out against the petitioners. Therefore, it was prayed that the present petition be allowed and the F.I.R. and proceedings arising out of the F.I.R. be quashed.

I have heard Mr Prajwal Sharma, learned counsel for the petitioners and Mr Lokender Kutlehria, learned Additional Advocate General, for respondent No.1/State.

Mr Prajwal Sharma, learned counsel for the petitioners, submitted that the petitioners are innocent and they were falsely implicated. F.I.R contains vague allegations against the petitioners. They had not participated in the commission of a crime. The continuation of the proceedings would amount to an abuse of the process of the Court. Hence, he prayed that the present petition be allowed and the F.I.R. and consequential proceedings be quashed.

Mr Lokender Kutlehria, learned Additional Advocate General, for respondent No.1, submitted that the police registered the F.I.R. and checked the CCTV footage. The petitioners were found to be involved in the commission of the crime; therefore, the charge sheet was filed before the Court. This Court should not exercise the inherent jurisdiction when the matter is pending before the learned Trial Court. Hence, he prayed that the present petition be dismissed.

I have given considerable thought to the submissions made at the bar and have gone through the records carefully.

The law relating to quashing of FIR was explained by the Hon’ble Supreme Court in B.N. John v. State of U.P. , 2025 SCC OnLine SC 7 as under: -

“7. As far as the quashing of criminal cases is concerned, it is now more or less well settled as regards the principles to be applied by the court. In this regard, one may refer to the decision of this Court in State of Haryana v. Ch. Bhajan Lal , 1992 Supp (1) SCC 335, wherein this Court has summarised some of the principles under which FIR/complaints/criminal cases could be quashed in the following words:

“102. In the backdrop of the interpretation of the various relevant provisions of the Code under Chapter XIV and of the principles of law enunciated by this Court in a series of decisions relating to the exercise of the extraordinary power under Article 226 or the inherent powers under Section 482 of the Code which we have extracted and reproduced above, we give the following categories of cases by way of illustration wherein such power could be exercised either to prevent abuse of the process of any court or otherwise to secure the ends of justice, though it may not be possible to lay down any precise, c