State of Haryana v. Bhajan Lal

Facts

• Bhajan Lal (former Chief Minister of Haryana) was charged with corruption.
• Multiple FIRs were registered against him.
• He challenged the FIRs before the High Court seeking quashing.
• The Supreme Court took the opportunity to enumerate guidelines for exercise of quashing power.

Issues

1. In what categories of cases should the High Court exercise inherent power to quash FIR or criminal proceedings?
2. What are the principles governing this exercise?

Held

• Allegations in FIR, taken at face value, do not prima facie constitute any offence or disclose a case against the accused.
• Allegations are so absurd and inherently improbable that no prudent person can reach a conclusion of guilt.
• Dispute is purely civil with no criminal element, and criminal law is being misused.
• Criminal proceedings are manifestly attended with mala fide or instituted with an ulterior motive for wreaking vengeance.
• Express legal bar prevents institution of proceedings (e.g., absence of sanction under S.197 CrPC / S.218 BNSS).

Ratio Decidendi

The inherent power to quash exists to prevent abuse of the criminal justice process. Criminal law should not be used as a weapon of harassment. The High Court must examine whether permitting the proceedings to continue would be an abuse of process or contrary to the interests of justice.