Rocky v. State of Telangana 2025 INSC 1384 - BNSS/CrPC - Quashing - Civil Nature

Code of Criminal Procedure 1973 - Section 482 : Bharatiya Nagarik Suraksha Sanhita 2023- Section 528 - Although courts must guard against giving criminal colour to civil disputes, the existence of civil remedies does not preclude criminal prosecution where the allegations disclose the essential ingredients of an offence. Civil and criminal proceedings may validly coexist if the factual matrix supports both.

Code of Criminal Procedure 1973 - Section 482 : Bharatiya Nagarik Suraksha Sanhita 2023- Section 528 -Quoted from Pradeep Kumar Kesarwani v. State of Uttar Pradesh : Structured four-step test to assess claims for quashing under Section 482 of the CrPC. The material relied on by the accused must be (i) of sterling and impeccable quality, (ii) sufficient to completely negate the allegations, (iii) uncontested or incapable of legitimate contest by the prosecution, and (iv) such that continuing the trial would amount to abuse of process. Unless all four tests are satisfied, quashing is unwarranted. (Para 27) Quashing cannot be premised on disputed documents whose validity is itself a matter in issue - At this stage, the Court cannot embark upon an evaluation of the reliability or genuineness of the allegations or the defence documents- Power under Section 482 of the CrPC is to be exercised sparingly, with circumspection and only in exceptional situations. Courts must avoid delving into disputed facts at the pre-trial stage. Interference is warranted only where the case clearly falls within the recognised parameters for quashing. (Para 26,30,32)

Constitution of India - Article 136- In appellate jurisdiction, Supreme Court does not ordinarily reappreciate evidence or revisit factual findings of the High Court unless the order suffers from manifest illegality, perversity or arbitrariness. (Para 33)