FIR Can Be Quashed If Allegations Made In Complaint Are Absurd & Inherently Improbable: Jharkhand HC
📝 Background of the Case
A petition was filed under Section 482 CrPC seeking quashing of an FIR.
The petitioner contended that the allegations in the FIR were absurd, fanciful, and inherently improbable, making the initiation of criminal proceedings malicious and vexatious.
The Jharkhand High Court considered whether such FIRs could be quashed even at the threshold, without waiting for trial.
⚖️ Court’s Reasoning
Power Under Section 482 CrPC:
Section 482 allows High Courts to quash FIRs or criminal proceedings to prevent abuse of process of law or to secure ends of justice.
The Court emphasized that this power is extraordinary, to be exercised sparingly and judiciously, but is essential to prevent harassment of innocent persons.
Test of Absurdity & Improbability:
If allegations are self-contradictory, impossible, or inherently improbable, a criminal trial would serve no purpose and would waste judicial time.
FIRs based on such allegations amount to malicious prosecution, and quashing is justified.
Balancing Public Interest:
The Court must ensure that quashing does not undermine legitimate complaints.
Only when allegations are patently absurd or cannot be accepted at any stretch of imagination, quashing is appropriate.
Avoiding Unnecessary Harassment:
Proceeding with inherently improbable allegations would subject the accused to harassment, damage reputation, and violate principles of natural justice.
📜 Relevant Case Laws
State of Haryana v. Bhajan Lal (1992) Supp (1) SCC 335
Landmark case laying down broad guidelines for quashing FIRs.
FIR can be quashed if allegations are frivolous, vexatious, or made with mala fide intention.
Girishbhai v. State of Gujarat (2007) 4 SCC 648
SC held that FIRs based on improbable allegations can be quashed to prevent abuse of process.
R.K. Jain v. State of Haryana (2010) 10 SCC 690
Court reiterated that quashing is justified where allegations are manifestly absurd or cannot constitute any offence.
Jharkhand HC Judgment (Current Case)
FIR was quashed because allegations were absurd, fanciful, and inherently improbable, with no prima facie case made out.
🏛️ Key Holding
FIR can be quashed if allegations are absurd, fanciful, or inherently improbable.
Quashing is justified to prevent abuse of process of law and harassment of the accused.
Courts must carefully balance the interest of complainant and accused to ensure justice is served.
🔑 Takeaways
Section 482 CrPC empowers courts to quash FIRs in extraordinary situations.
Allegations that are patently impossible, absurd, or inherently improbable justify quashing.
Quashing prevents harassment, malicious prosecution, and wastage of judicial time.
Courts must not quash FIRs lightly; only obvious absurdities or mala fide complaints qualify.
Maintains balance between public interest and protection of innocent persons.
In short: An FIR can be quashed if the allegations are absurd or inherently improbable, as such proceedings would only harass the accused and serve no purpose in the interest of justice.
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