A Comprehensive Legal Research Article Incorporating Supreme Court Jurisprudence from Bhajan Lal to 2024

Abstract

Criminal law is intended to protect society from real offences. In practice, however, criminal proceedings are sometimes deployed as instruments of harassment, private revenge, commercial coercion, matrimonial counter-pressure, reputation damage, and forced settlement. The punishment in such cases often begins long before trial: arrest anxiety, social stigma, legal expenses, business disruption, family pressure, and reputational injury.

Section 482 of the Code of Criminal Procedure, 1973 (CrPC), and its successor provision under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), preserve the inherent power of the High Court to prevent abuse of process and secure the ends of justice.

This article examines the positive jurisprudence on quashing of FIRs, complaints, charge sheets, and criminal proceedings where the criminal process is misused as a weapon of harassment. It classifies leading Supreme Court decisions into six practical categories: (i) civil disputes converted into criminal proceedings; (ii) FIRs pursued despite charge sheet; (iii) breach of contract disguised as cheating; (iv) matrimonial over-implication; (v) malicious prosecution and vengeance FIRs; and (vi) settlement of private disputes. It then examines the countervailing judicial limitations against which these powers must be exercised.

1.  Introduction: When Process Becomes Punishment

A false or malicious criminal case does not harm the accused only upon conviction. The process itself can become punishment. A person may suffer arrest, bail conditions, repeated court appearances, professional damage, family humiliation, social stigma, and financial exhaustion long before guilt is tested at trial.

This reality gives Section 482 CrPC and Section 528 BNSS their practical importance. These provisions do not create an appellate shortcut for every accused person. They preserve the High Court’s inherent power to prevent abuse of the process of court and to secure the ends of justice.

The central question in any quashing petition is not whether the accused claims innocence. The real question is whether the FIR, complaint, charge sheet, and admitted or unimpeachable material disclose the legal ingredients of a criminal offence. If they do not — or if the proceeding is clearly mala fide, oppressive, absurd, or civil in substance — the High Court may and must intervene.

2.  The Correct Legal Provisions: Section 482 CrPC and Section 528 BNSS

Section 482 CrPC preserved the inherent powers of the High Court under the Code of Criminal Procedure, 1973. Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 now carries forward the same principle. Under both provisions, the High Court may pass any order necessary:

1. to give effect to any order under the criminal procedure law;
2. to prevent abuse of the process of any court; or
3. to otherwise secure the ends of justice.

A critical terminological clarification: the expression “IPC 482” is legally incorrect. The Indian Penal Code is the substantive criminal law. The inherent power of the High Court derives from the procedural code. The correct expression is “Section 482 CrPC” for proceedings under the old code and “Section 528 BNSS” for proceedings under the new criminal procedure framework.

3.  Foundational Doctrine: State of Haryana v. Bhajan Lal

The starting point of any research on quashing of FIRs is State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335. This landmark judgment represents the constitutional grammar of quashing jurisprudence. Almost every subsequent decision either applies, explains, limits, or reaffirms it.

The Supreme Court laid down illustrative categories where the High Court may quash criminal proceedings. For the topic of criminal process as harassment, the most important Bhajan Lal categories are:

• Where allegations in the FIR or complaint, even if taken at face value and accepted in their entirety, do not constitute any offence;
• Where the FIR and accompanying material do not disclose a cognizable offence;
• Where uncontroverted allegations and evidence collected do not disclose commission of any offence;
• Where the allegations are so absurd or inherently improbable that no prudent person can ever reach a just conclusion that there is sufficient ground for proceeding;
• Where there is an express legal bar to the proceeding; and
• Where the proceeding is manifestly attended with mala fide and has been instituted with an ulterior motive for vengeance, private grudge, or harassment.

4.  Category One: Civil Disputes Converted into Criminal Proceedings

One of the most prevalent abuses of criminal law occurs when a civil, contractual, commercial, property, or monetary dispute is dressed in criminal language — typically as cheating, criminal breach of trust, forgery, or criminal conspiracy. The objective is usually not conviction but pressure: compelling a settlement, damaging credit, or exhausting the opponent financially.

4.1  G. Sagar Suri v. State of U.P., (2000) 2 SCC 636

In G. Sagar Suri, the Supreme Court delivered an early and emphatic warning: criminal proceedings should not be used as a shortcut for civil remedies. If the dispute is essentially civil in nature and the criminal process is being deployed to apply pressure, the High Court has not only the power but the duty to intervene under Section 482 CrPC.

The case establishes the foundational proposition that criminal courts must not become instruments of private recovery pressure or settlement coercion.

CASE	G. Sagar Suri v. State of U.P., (2000) 2 SCC 636 Criminal proceedings cannot serve as a shortcut for civil remedies. Where the dispute is essentially civil, the High Court must intervene under Section 482 CrPC.

4.2  Indian Oil Corporation v. NEPC India Ltd., (2006) 6 SCC 736

Indian Oil Corporation is a leading authority on the misuse of criminal proceedings in commercial disputes. The Supreme Court observed a growing tendency to convert purely civil disputes into criminal complaints, and held that efforts to settle civil claims by applying pressure through criminal prosecution must be deprecated and discouraged.

This decision is directly applicable wherever a commercial disagreement — whether relating to breach of contract, unpaid dues, or business failure — is sought to be prosecuted as cheating or criminal breach of trust.

CASE	Indian Oil Corporation v. NEPC India Ltd., (2006) 6 SCC 736 The growing tendency to convert civil disputes into criminal complaints must be deprecated. Criminal process is not a legitimate tool for commercial pressure.

4.3  Mohd. Ibrahim v. State of Bihar, (2009) 8 SCC 751

Mohd. Ibrahim is particularly important in property and document disputes. The Supreme Court clarified that a civil dispute does not automatically transform into a criminal offence merely because the allegations are framed in criminal language. Where the legal ingredients of cheating, forgery, or criminal breach of trust are genuinely absent, the criminal prosecution becomes an abuse of process.

4.4  Prof. R.K. Vijayasarathy v. Sudha Seetharam, (2019) 16 SCC 739

The Supreme Court quashed criminal proceedings in this case where a civil dispute had been given a criminal colour despite the absence of the necessary ingredients of any Penal Code offence. The Court affirmed that the complaint must be examined as a whole, and where basic facts necessary to constitute a criminal offence are missing, continuation of prosecution amounts to abuse of the court’s process.

4.5  Anand Kumar Mohatta v. State (NCT of Delhi), (2019) 11 SCC 706

This decision combines three critical themes and is among the most instructive in the field.

First, the Supreme Court held that a quashing petition does not become untenable merely because a charge sheet has been filed during its pendency. Section 482 CrPC is not confined to the FIR stage alone. If the proceeding is abusive, the abuse may intensify once an FIR matures into a charge sheet.

Second, on the merits, the dispute arose out of a 1993 development agreement concerning a deposit of Rs. 1 crore. Construction could not proceed because the property fell within the Lutyens Bungalow Zone and high-rise development became impermissible. The complainant alleged criminal breach of trust under Section 406 IPC. The Supreme Court found that neither entrustment nor dishonest misappropriation was established. The FIR and charge sheet were quashed.

CASE	Anand Kumar Mohatta v. State (NCT of Delhi), (2019) 11 SCC 706 Section 482 CrPC is not restricted to the FIR stage. A charge sheet does not cure a fundamentally abusive prosecution. Where ingredients of the offence are absent, quashing is warranted.

5.  Category Two: Quashing After Charge Sheet

A common procedural objection raised by complainants and the prosecution is that once a charge sheet is filed, a petition challenging the FIR becomes infructuous. The Supreme Court has rejected this rigid position consistently.

5.1  Joseph Salvaraj A. v. State of Gujarat, (2011) 7 SCC 59

In Joseph Salvaraj, the Supreme Court held that even where a charge sheet is filed during the pendency of a quashing petition, the High Court retains full jurisdiction to examine whether the offences are prima facie made out from the totality of the FIR, charge sheet, documents, and material. The filing of a charge sheet does not foreclose the jurisdiction under Section 482 CrPC.

5.2  Anand Kumar Mohatta v. State (NCT of Delhi), (2019) 11 SCC 706

Anand Kumar Mohatta reaffirmed this position with clarity. The Supreme Court expressly held that it would be erroneous to say that the High Court can interfere when allegations are at the FIR stage but loses jurisdiction once those allegations are converted into a charge sheet. Malicious prosecution should not survive merely by virtue of an investigation report.

This principle is of fundamental practical importance: the accused cannot be denied relief under Section 482 CrPC simply because the investigating agency has mechanically filed its report while the quashing petition was pending.

6.  Category Three: Breach of Contract Disguised as Cheating

Every breach of contract is not cheating. The essential distinction is one of intention. To constitute cheating under Section 415/420 IPC, dishonest or fraudulent intention must have existed from the very inception of the transaction. A subsequent failure to perform a contractual obligation — however reprehensible commercially — does not automatically attract criminal liability.

6.1  Hridaya Ranjan Prasad Verma v. State of Bihar, (2000) 4 SCC 168

This is the leading authority on the distinction between breach of contract and cheating. The Supreme Court held that the intention of the accused at the moment of inducement is the critical question. Where dishonest intention at the inception of the transaction is absent, a mere breach of contractual obligation will not constitute cheating under the Penal Code.

CASE	Hridaya Ranjan Prasad Verma v. State of Bihar, (2000) 4 SCC 168 The accused’s dishonest intention at the time of inducement is the decisive test. Absence of this element at inception means a breach of contract cannot constitute cheating.

6.2  V.Y. Jose v. State of Gujarat, (2009) 3 SCC 78

V.Y. Jose further entrenches the distinction. The Supreme Court held that contractual disputes must not be criminalised unless fraudulent intention is established from the beginning of the transaction. A mere failure to keep a promise, or a change of financial circumstances, does not by itself establish the offence of cheating.

6.3  Mitesh Kumar J. Sha v. State of Karnataka (2021)

This case is particularly valuable in builder, developer, and real estate disputes. It demonstrates the judicial approach where disputes relating to development rights, delivery of flats, contractual performance, and monetary recovery are given criminal colour. The High Court must examine whether genuine criminal ingredients are disclosed, or whether the FIR has been registered as a mechanism of pressure to compel settlement or payment.

7.  Category Four: Matrimonial Disputes and Over-Implication of Relatives

Matrimonial cruelty is a serious offence under Section 498A IPC, and genuine victims are entitled to full protection of the law. However, the Supreme Court has repeatedly identified and addressed a distinct pattern of abuse: the mechanical or strategic implication of distant relatives of the husband in criminal complaints, through vague, general, and omnibus allegations devoid of specific particulars.

7.1  Preeti Gupta v. State of Jharkhand, (2010) 7 SCC 667

Preeti Gupta represents an early and significant judicial warning about the exaggerated implication of relatives in Section 498A IPC cases. The Supreme Court observed that courts must scrutinise complaints with care where large numbers of relatives — including those residing far away — are implicated without any specific allegations relating to their individual conduct.

7.2  Geeta Mehrotra v. State of U.P., (2012) 10 SCC 741

In Geeta Mehrotra, the Supreme Court quashed proceedings against relatives where allegations were entirely general and lacked specific role attribution. The case establishes the clear principle that casual, incidental, or omnibus references to family members in a matrimonial complaint are insufficient to subject those persons to criminal trial.

7.3  Kahkashan Kausar @ Sonam v. State of Bihar, (2022) 6 SCC 599

Kahkashan Kausar is one of the most authoritative modern decisions on matrimonial over-implication. The Supreme Court quashed proceedings against in-laws where the allegations against them were general, omnibus, and devoid of specific particulars regarding any individual act of cruelty. The Court sounded a clear warning against the misuse of Section 498A IPC as a tool to settle personal scores within the family.

CASE	Kahkashan Kausar @ Sonam v. State of Bihar, (2022) 6 SCC 599 General, omnibus allegations against in-laws lacking specific particulars of each person’s conduct cannot sustain criminal proceedings. Section 498A IPC must not become an instrument for settling personal scores.

7.4  M. Nirupama v. State of Andhra Pradesh (2024)

M. Nirupama continues the same principled line of authority. The Supreme Court held that relatives cannot be forced to face criminal proceedings on the basis of vague, general, and omnibus allegations, reaffirming the principle established in the earlier decisions.

7.5  Dara Lakshmi Narayana v. State of Telangana (2024)

This decision extends the principle to its logical breadth: the husband’s entire family must not be mechanically dragged into matrimonial prosecution. The High Court is duty-bound to examine whether the complaint contains specific, individual allegations disclosing the particular role of each accused in the commission of the offence.

8.  Category Five: Malicious Prosecution, Reputation Damage, and Vengeance FIRs

Some criminal complaints are not filed to redress a genuine offence. Their true purpose is to damage reputation, create bargaining pressure, trigger arrest anxiety, silence a critic, settle old scores, compel commercial concessions, or inflict social stigma. These proceedings represent the most direct weaponisation of criminal law.

8.1  Pepsi Foods Ltd. v. Special Judicial Magistrate, (1998) 5 SCC 749

Pepsi Foods is a powerful statement on the gravity of criminal process at its very inception. The Supreme Court held that summoning an accused in a criminal case is a serious matter with serious consequences. Criminal law cannot be set into motion casually or mechanically. The Magistrate is duty-bound to apply mind before issuing summons or process.

This decision is fundamental to demonstrating that even the initiation of criminal process — before any trial, before any conviction — carries consequences that can damage a person’s professional reputation, business relationships, credit, and social standing.

8.2  Mahmood Ali v. State of U.P., Criminal Appeal No. 2341 of 2023

Mahmood Ali is particularly valuable for cases involving cleverly drafted complaints and malicious FIRs. The Supreme Court held that where the accused alleges that proceedings are frivolous, vexatious, or instituted with an ulterior motive, the court must examine the FIR with care and somewhat greater scrutiny.

Crucially, the Court acknowledged that FIRs may be drafted with care to appear legally sound on their face. The High Court is therefore not helpless merely because the complaint is written in proper criminal language. It may look at attending circumstances and the material collected during investigation to determine whether the prosecution is abusive in substance.

CASE	Mahmood Ali v. State of U.P., Criminal Appeal No. 2341 of 2023 Where proceedings are alleged to be frivolous or instituted with ulterior motive, the FIR must be examined with greater care. Clever drafting does not foreclose the High Court’s jurisdiction to look at the substance of the matter.

9.  Category Six: Settlement of Private Disputes

In some cases, criminal proceedings arise from private disputes that are subsequently resolved between the parties. The High Court may quash such proceedings where the offence is overwhelmingly private in nature and continuation of prosecution would serve no public purpose — amounting instead to persecution.

9.1  Gian Singh v. State of Punjab, (2012) 10 SCC 303

Gian Singh is the landmark case that clarified the relationship between the compounding power under Section 320 CrPC and the inherent power under Section 482 CrPC. The Supreme Court held that the High Court’s power under Section 482 CrPC is wider than the statutory compounding power. Even offences that are not compoundable under Section 320 CrPC may be quashed where the dispute is overwhelmingly private in character and continuation of proceedings would be futile or oppressive.

9.2  Narinder Singh v. State of Punjab, (2014) 6 SCC 466

Narinder Singh laid down detailed guidelines for quashing on the basis of compromise. The Court required consideration of: the nature and gravity of the offence; the stage of the proceedings; the likelihood of conviction; whether continuation would amount to oppression; and whether the settlement is genuine and voluntary.

9.3  State of Madhya Pradesh v. Laxmi Narayan, (2019) 5 SCC 688

Laxmi Narayan refined the applicable principles. The Court drew a clear distinction between offences that are essentially private or civil in character — including commercial, financial, partnership, matrimonial, or family disputes — which may be quashed on compromise, and heinous offences affecting society at large — including murder, rape, dacoity, and serious statutory offences — which cannot be quashed simply because the parties have reached a private settlement.

10.  The Key Test: Ingredients, Not Labels

A complainant may employ terms such as cheating, breach of trust, conspiracy, fraud, harassment, cruelty, or forgery. But criminal law depends on the presence of specific legal ingredients, not the labels attached by a complainant.

Offence	Essential Ingredients That Must Be Present
Cheating (S. 415/420 IPC)	Dishonest or fraudulent intention at the inception of the transaction
Criminal Breach of Trust (S. 405/406 IPC)	Entrustment of property + dishonest misappropriation or conversion
Criminal Conspiracy (S. 120A/120B IPC)	Agreement between two or more persons to commit an illegal act or a legal act by illegal means
Cruelty (S. 498A IPC)	Specific conduct amounting to cruelty — not vague dissatisfaction or family friction
Forgery (S. 463/465 IPC)	Making a false document with requisite intent to cause damage or injury
Abetment (S. 107/109 IPC)	Active instigation, conspiracy, or intentional aid — not mere presence or association

Therefore, in deciding any quashing petition, the High Court must ask: even if all the allegations in the complaint or FIR are accepted at face value and in their entirety, do they disclose the required legal ingredients of the offence alleged?

If the answer is no, continuation of the case is not merely inefficient — it is an abuse of the court’s process, and quashing becomes necessary to secure justice.

11.  The Protective Role of Section 482 CrPC and Section 528 BNSS

Section 482 CrPC and Section 528 BNSS serve a protective constitutional function. They prevent criminal law from degenerating into a private weapon. Their purpose is not to protect guilty persons from facing trial. Their purpose is to protect citizens from prosecutions that should never have been launched.

The High Court’s inherent power becomes especially important in the following circumstances:

• A civil dispute has been dressed as a criminal offence;
• A commercial disagreement has been converted into cheating or criminal breach of trust;
• Relatives are implicated in matrimonial litigation without specific, individual allegations;
• Criminal proceedings are filed primarily to damage reputation or create social stigma;
• The FIR is malicious, absurd, or inherently improbable;
• A charge sheet has been filed but the material still does not disclose any criminal offence;
• Criminal process is being used to force settlement, recovery, or commercial concessions; or
• Continuation of prosecution would amount to harassment, persecution, or institutional abuse.

12.  Limitations on Quashing: The Other Side of the Doctrine

The power to quash is wide, but it is not unlimited. The Supreme Court has repeatedly cautioned that Sections 482 CrPC and 528 BNSS cannot be converted into a substitute for trial, an appellate bypass, or a pre-trial acquittal mechanism.

12.1  No Mini-Trial

The High Court exercising jurisdiction under Section 482 CrPC must not evaluate disputed evidence, test the credibility of witnesses, or adjudicate on whether the prosecution will ultimately succeed. Where the allegations disclose a prima facie cognizable offence, disputed questions of fact must ordinarily be left to trial.

12.2  Investigation Should Not Be Routinely Halted

In Neeharika Infrastructure v. State of Maharashtra, (2021), the Supreme Court sounded a strong warning: quashing of FIRs at the investigation stage should be an exception and not the norm. Courts should not routinely stop investigation merely because the accused disputes the allegations or characterises the complaint as motivated.

12.3  Serious Offences Cannot Be Privatised

In State of M.P. v. Laxmi Narayan, the Supreme Court held that heinous and serious offences — including murder, rape, dacoity, corruption, and serious offences under special statutes — cannot be quashed merely on account of a private compromise between the accused and the complainant. Such offences affect society as a whole and are not merely private in character.

12.4  Settlement Alone Is Insufficient

Even where parties settle their dispute, the High Court must independently examine the nature of the offence, its social impact, the stage of the case, the antecedents of the accused, and whether the settlement is genuine, voluntary, and free from coercion.

12.5  Defence Material Is Ordinarily Limited

The accused cannot ordinarily rely on disputed defence material at the quashing stage. However, the Court may take into account unimpeachable, admitted, or documentary material that clearly demonstrates that continuation of prosecution would be abusive — such as official records, registered documents, public records, or material collected during investigation itself.

13.  Classification of Jurisprudence for Research Use

The following classification organises the leading Supreme Court decisions by category for ease of research, reference, and citation:

Category	Leading Cases
A. Civil/Commercial Dispute Converted into Criminal Case	G. Sagar Suri (2000); Indian Oil Corporation (2006); Mohd. Ibrahim (2009); Prof. R.K. Vijayasarathy (2019); Anand Kumar Mohatta (2019); Mitesh Kumar J. Sha (2021)
B. Quashing After Charge Sheet	Joseph Salvaraj A. (2011); Anand Kumar Mohatta (2019)
C. Breach of Contract Disguised as Cheating	Hridaya Ranjan Prasad Verma (2000); V.Y. Jose (2009); Indian Oil Corporation (2006); Mitesh Kumar J. Sha (2021)
D. Matrimonial Over-Implication of Relatives	Preeti Gupta (2010); Geeta Mehrotra (2012); Kahkashan Kausar (2022); M. Nirupama (2024); Dara Lakshmi Narayana (2024)
E. Malicious Prosecution and Vengeance FIRs	State of Haryana v. Bhajan Lal (1992); Pepsi Foods (1998); Mahmood Ali (2023)
F. Settlement of Private Disputes	Gian Singh (2012); Narinder Singh (2014); State of M.P. v. Laxmi Narayan (2019)
G. Limitations on Quashing	Neeharika Infrastructure (2021); State of M.P. v. Laxmi Narayan (2019); CBI v. Aryan Singh

14.  Research Thesis

Section 482 CrPC and Section 528 BNSS are not escape routes for accused persons in genuine criminal cases. They are judicial safety valves against the abuse of criminal process. Where a criminal case is filed to harass, coerce settlement, damage reputation, over-implicate relatives, convert a civil dispute into criminal prosecution, or continue a legally baseless case even after charge sheet, the High Court has the duty to intervene. The guiding test is not the accused’s denial of guilt, but whether the complaint, FIR, charge sheet, and admitted material disclose the legal ingredients of a criminal offence. Where they do not, criminal proceedings cease to be prosecution and become persecution — and quashing becomes necessary to secure justice.

15.  Conclusion

The power of quashing under Section 482 CrPC and Section 528 BNSS reflects a deeper constitutional principle: criminal law must not be allowed to degenerate into a private weapon. The process of criminal prosecution carries severe and lasting consequences even before any conviction is recorded. Therefore, where allegations are inherently improbable, legally deficient, mala fide, civil in substance, or designed to harass, the High Court must prevent abuse of the court’s process.

At the same time, this power must be exercised with discipline and judicial restraint. High Courts cannot conduct mini-trials, weigh contested evidence, or prematurely terminate genuine investigations. The balance is delicate but doctrinally clear: genuine criminality must proceed to trial; weaponised criminality must be stopped at the threshold.

The modern law of quashing is not anti-complainant and not pro-accused. It is anti-abuse. Its singular purpose is to ensure that criminal courts remain forums of justice — not instruments of harassment, commercial pressure, or private vengeance.

Table of Cases

Case Citation	Key Principle
State of Haryana v. Bhajan Lal 1992 Supp (1) SCC 335	Foundational categories for quashing of FIRs; constitutional grammar of quashing jurisprudence
Pepsi Foods Ltd. v. Special Judicial Magistrate (1998) 5 SCC 749	Summoning an accused is a serious matter; criminal process cannot be set in motion casually
G. Sagar Suri v. State of U.P. (2000) 2 SCC 636	Criminal proceedings cannot serve as a shortcut for civil remedies
Hridaya Ranjan Prasad Verma v. State of Bihar (2000) 4 SCC 168	Dishonest intention at inception is the decisive test distinguishing cheating from breach of contract
Indian Oil Corporation v. NEPC India Ltd. (2006) 6 SCC 736	Commercial disputes dressed as criminal complaints must be deprecated and discouraged
Mohd. Ibrahim v. State of Bihar (2009) 8 SCC 751	Civil disputes do not become criminal merely by using criminal language in pleadings
V.Y. Jose v. State of Gujarat (2009) 3 SCC 78	Contractual disputes must not be criminalised absent fraudulent intention from inception
Preeti Gupta v. State of Jharkhand (2010) 7 SCC 667	Large-scale implication of relatives in matrimonial complaints requires careful judicial scrutiny
Joseph Salvaraj A. v. State of Gujarat (2011) 7 SCC 59	Filing of charge sheet does not defeat a pending quashing petition
Gian Singh v. State of Punjab (2012) 10 SCC 303	Section 482 CrPC power wider than Section 320 CrPC; private disputes may be quashed on compromise
Geeta Mehrotra v. State of U.P. (2012) 10 SCC 741	General allegations without specific role attribution cannot sustain criminal proceedings against relatives
Narinder Singh v. State of Punjab (2014) 6 SCC 466	Guidelines for quashing on compromise: nature of offence, stage, likelihood of conviction
Prof. R.K. Vijayasarathy v. Sudha Seetharam (2019) 16 SCC 739	Civil disputes given criminal colour without the necessary ingredients must be quashed
Anand Kumar Mohatta v. State (NCT of Delhi) (2019) 11 SCC 706	Section 482 CrPC applies at all stages; charge sheet does not cure an abusive prosecution
State of M.P. v. Laxmi Narayan (2019) 5 SCC 688	Heinous offences affecting society cannot be quashed on compromise
Neeharika Infrastructure v. State of Maharashtra (2021)	Quashing at investigation stage is an exception; courts should not routinely stop investigation
Kahkashan Kausar @ Sonam v. State of Bihar (2022) 6 SCC 599	Omnibus allegations against in-laws insufficient; Section 498A must not be misused for vengeance
Mahmood Ali v. State of U.P. Criminal Appeal No. 2341 of 2023	FIRs alleged to be malicious must be examined with greater scrutiny; clever drafting does not foreclose jurisdiction
M. Nirupama v. State of Andhra Pradesh (2024)	Vague, omnibus allegations against relatives cannot sustain criminal proceedings
Dara Lakshmi Narayana v. State of Telangana (2024)	Each accused’s specific role must be disclosed; mechanical implication of entire family is impermissible