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Sau. Kamal Shivaji Pokarnekar vs The State Of Maharashtra on 12 February, 2019

32. In view of the above said definitions and also authoritative pronouncements with regard to powers of this Court under Section 482 of Cr.P.C. as discussed supra, there are several aspects which are to be investigated by the Investigating Officer. The matter is at crime stage. The Hon'ble Apex Court in Sau. Kamal Shivaji Pokarnekar v. State of Maharashtra13 has categorically held that quashing criminal proceedings was called for only in a case where complaint did not disclose any offence, or was frivolous, vexatious, or oppressive. If allegations set out in complaint did not constitute offence of which cognizance had been taken by Magistrate, it was open to High Court to quash same. It was not necessary that, a meticulous analysis of case should be done before trial to find out whether case would end in conviction or acquittal. If it appeared on a reading of complaint and consideration of allegations therein, in light of the statement made on oath that the ingredients of the offence are disclosed, there would be no justification for High Court to interfere. The defences that might be available, or facts/aspects which when established during trial, might lead to acquittal, were not grounds for quashing complaint at threshold. At that stage, only question relevant was whether averments in complaint spell out ingredients of a 13 . AIR 2019 SC 847 KL,J Crl.P. No.2745 of 2020 & batch 19 criminal offence or not. The Court has to consider whether complaint discloses that prima facie, offences that were alleged against Respondents. Correctness or otherwise of said allegations had to be decided only in trial. At initial stage of issuance of process, it was not open to Courts to stifle proceedings by entering into merits of the contentions made on behalf of Accused. Criminal complaints could not be quashed only on ground that, allegations made therein appear to be of a civil nature. If ingredients of offence alleged against Accused were prima facie made out in complaint, criminal proceeding shall not be interdicted.
Supreme Court of India Cites 6 - Cited by 1870 - L N Rao - Full Document
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