Mohommad Baks vs State Of Chhattisgarh on 26 May, 2026

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    Chattisgarh High Court

    Mohommad Baks vs State Of Chhattisgarh on 26 May, 2026

    Author: Parth Prateem Sahu

    Bench: Parth Prateem Sahu

                                                 1
    
    
    SYED
    ROSHAN
    ZAMIR
    ALI
    Digitally
    signed by
    SYED
                                                           2026:CGHC:23475-DB
    ROSHAN
    ZAMIR ALI                                                                 NAFR
    
                        HIGH COURT OF CHHATTISGARH AT BILASPUR
    
    
                                      CRMP No. 1471 of 2026
    
                  1. Mohommad Baks S/o Sameed Ansari Aged About 38 Years
                      R/o Village - Anirudhpur Police Station - Ramchandrapur
                      Distt- Balrampur-Ramanujganj (C.G.)
                                                                        ... Petitioner
                                              versus
                  1. State of Chhattisgarh Through Station House Officer Police
                      Station    Ramchandrapur    Distt-   Balrampur-   Ramanujganj
                      (C.G.)
                  2. Khileshwar Ram S/o Budheshwar Ram Aged About 33 Years
                      R/o Village- Prem Nagar Police Station Karondha Distt-
                      Balrampur- Ramanujganj (C.G.)
                                                                   ... Respondents
                For Petitioner       :   Mr. Amarnath Pandey, Advocate
                For Respondents      :   Mr. Ashish Shukla, Additional Advocate General
    
                         DB: Hon'ble Mr. Justice Parth Prateem Sahu,J
                             & Hon'ble Mr. Justice Bibhu Datta Guru, J
                                          Order on Board
    
                Per Parth Prateem Sahu, J
    
    

    26.05.2026

    1. Petitioner has invoked inherent jurisdiction of this Court under

    SPONSORED

    Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023
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    for short ‘BNSS’) seeking quashment of charge sheet

    No.25/2025 filed before the learned Judicial Magistrate 1 st

    Class Ramanujganj, District Balrampur Ramanujganj in

    connection with FIR No.3/2025 registered against the

    petitioner at Police Station Ramchandrapur for the offence

    punishable under Sections 331 (3), 296, 132, 174 of the

    Bharatiya Nyay Sanhita, 2023 (for short ‘BNS’) Section 3 of

    the Prevention of Damage to Public Property Act 1984 and

    Section 7 () of the Chhattisgarh Local Authorities (Electoral

    Offences) Act, 1964. Petitioner has also prayed for setting

    aside of the order dated 13.10.2025 by which learned

    Magistrate has taken cognizance on the final report submitted

    by the police.

    2. Facts of the case, in brief, are that on 5.3.2025 respondent

    No.2-complainant submitted a written complaint before the

    concerned police station alleging that when the complainant

    was engaged in the duty of panchayat election at Booth

    No.115, village Ramchandrapur, 100-150 people including

    petitioner herein reached there, entered the polling booth

    centre while abusing them filthily, broke open two locks of

    booth centre and tried to snatch election materials and

    thereby they have caused obstruction in discharge of official

    duty by the complainant and other government officials who

    were on election duty. Based on aforesaid complaint, FIR
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    bearing No.03/2025 was registered against petitioner and

    100-150 others for the offence under Sections 331 (3), 296,

    132, 174 of the BNS; Section 3 of the Prevention of Damage

    to Public Property Act 1984 and Section 7 ([k) of the

    Chhattisgarh Local Authorities (Electoral Offences) Act, 1964.

    In the course of investigation, police recorded statement of

    witnesses under Section 180 of BNSS (Section 161 CrPC) as

    also supplementary statement and on completion of

    investigation, the police submitted charge sheet on which the

    concerned Court has taken cognizance on 13.10.2025

    against the petitioner for the offence as aforementioned.

    3. Learned counsel for petitioner would submit that petitioner

    has been falsely implicated in instant crime due to political

    rivalry as he is elected as a Member of Janpad Panchayat

    Ramchandrapur in two consecutive terms. He submits that in

    the panchayat election of 2025 petitioner has defeated the

    candidate of ruling party in the State, due to which they were

    annoyed with the petitioner and therefore, they colluded with

    the Presiding Officer and got lodged a false complaint against

    the petitioner. He submits that FIR against the petitioner is

    registered with inordinate delay i.e. after 10 days from the

    date of alleged incident, and despite due knowledge, delay of

    10 days has not been explained by the complainant. Delay of

    10 days in reporting of alleged incident, particularly when
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    police station is at a distance of just 500 meter from the place

    of alleged incident, clearly indicates that FIR is not a

    spontaneous document but it is the result of deliberations and

    afterthought.

    4. He further submits that the order taking cognizance against

    the petitioner is wholly illegal, arbitrary and contrary to the

    settled principles in this regard, inasmuch as the learned trial

    Court has failed to properly appreciate the material available

    on record and has mechanically taken cognizance on the

    report submitted by police without there being sufficient

    ground for proceeding. He further submits that while taking

    cognizance, learned trial Court has not applied its judicial

    mind and failed to consider whether there exists a prima facie

    case against the petitioner. Hence, the order is cryptic and

    non-speaking, and does not reflect any reasoning as to how

    the ingredients of the alleged offences are made out.

    5. He next contended that the entire prosecution case, even if

    taken at its face value and accepted in its entirety, does not

    disclose the commission of any offence much less the

    offences for which final report is submitted. Hence, it is

    prayed that the charge sheet No.25/2025 submitted against

    the petitioner and all subsequent proceedings initiated

    thereon be quashed.

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    6. On the other hand, learned State Counsel opposing

    submissions of learned counsel for petitioner, would submit

    that present petition seeking quashment of FIR, charge-sheet

    and the order taking cognizance on final report, is wholly

    misconceived and not maintainable in law. FIR against the

    petitioner is registered based on written complaint lodged by

    the Presiding Officer engaged in panchayat election duty.

    After completion of investigation, charge-sheet was filed

    before the competent Court and learned trial Court has rightly

    taken cognizance after due consideration of material available

    before it and after due application of mind. He also submits

    that factual controversy cannot be considered at this moment.

    FIR and the outcome of investigation, prima facie disclose the

    commission of cognizable offences. At this stage, meticulous

    appreciation of evidence or adjudication on disputed facts is

    impermissible. Hence, the petition is liable to be dismissed.

    7. Heard learned counsel for the parties and perused the

    documents filed along with petition.

    8. Upon a perusal of the FIR and material placed on record, this

    Court finds that there are clear and specific allegations

    attributable to petitioner about causing hindrance in

    performance of official duty by the complainant and others,

    who were on election duty. It is specifically mentioned in the

    complaint that petitioner along with 100-150 persons broke
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    open locks, entered Polling Booth No.115 of village

    Ramchandrapur, hurled filthy abuses at the government

    officials, who were on election duty and also tried to snatch

    election materials. Statement of witnesses is also recorded by

    police under Section 180 of BNSS and thereafter police

    submitted final report before learned Magistrate. Thus, there

    is prima facie material against the petitioner that he had tried

    to obstruct the complainant from doing his official duty.

    9. This Court while hearing the matter under Section 528 BNSS

    at the initial stage of proceedings, cannot examine

    genuineness of statement, allegations made in FIR in

    question. In case of Teeja Devi vs. State of Rajasthan,

    reported in (2014) 15 SCC 221 Hon’ble Supreme Court has

    held as under :

    “5. It has been rightly submitted by the learned
    counsel for the appellant that ordinarily power under
    Section 482 CrPC should not be used to quash an
    FIR because that amounts to interfering with the
    statutory power of the police to investigate a
    cognizable offence in accordance with the
    provisions of CrPC. As per law settled by a catena
    of judgments, if the allegations made in the FIR
    prima facie disclose a cognizable offence,
    interference with the investigation is not proper and
    it can be done only in the rarest of rare cases where
    the court is satisfied that the prosecution is
    malicious and vexatious.”

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    10. In case at hand, though submission is made by learned

    counsel for petitioner of false implication, however, upon

    perusal of the documents enclosed along with the petition, it

    is apparent that the complainant is a Presiding Officer of

    Polling Booth No.115. He is a government servant holding

    post of Lecturer. Other employees engaged in election duty

    along with complainant are also Teachers. Statement of Cook

    of Anganbadi Centre is also recorded under Section 180 of

    BNSS. Upon going through the entire material at this stage,

    we are unable to accept the contention of learned counsel for

    petitioner that the report lodged against him is vexatious. It is

    subject-matter of evidence.

    11. So far as submission of learned counsel for petitioner that

    incident is dated 23.2.2025 and FIR was lodged on 5.3.2025

    with delay, is concerned, it cannot be overlooked that

    complainant is a government servant, he was deputed in

    election duty as Presiding Officer of Polling Booth No.115 of

    village Ramchandrapur. In written complaint, there is mention

    that due to act of petitioner and other group of persons, they

    became afraid and have intimated the police of Police Station

    Ramchandrapur and the Zonal Officer, upon which the Police

    and Zonal Officer came there and intervened. In the facts of

    the case and nature of allegation, ground of delay is to be

    appreciated by learend trial Court after recording of evidence
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    in a trial where petitioner will have an opportunity to cross-

    examine the witnesses on that point also. In the given facts

    of the case and nature of allegations, we do not find it

    appropriate to accept said ground raised on behalf of

    petitioner for quashment of criminal proceedings at this stage.

    12. In case of State of Haryana and others vs Bhajanlal and

    others, reported in (1992) Supp (1) 335, Hon’ble Supreme

    Court has laid down the guidelines for exercising inherent

    powers under Section 482 CrPC, corresponding to Section

    528 of BNSS, which are as follows:-

    “102. In the backdrop of the interpretation of the
    various relevant provisions of the Code under Chapter
    XIV and of the principles of law enunciated by this
    Court in a series of decisions relating to the exercise
    of the extraordinary power under Article 226 or the
    inherent powers under Section 482 of the Code which
    we have extracted and reproduced above, we give the
    following categories of cases by way of illustration
    wherein such power could be exercised either to
    prevent abuse of the process of any court or otherwise
    to secure the ends of justice, though it may not be
    possible to lay down any precise, clearly defined and
    sufficiently channelised and inflexible guidelines or
    rigid formulae and to give an exhaustive list of myriad
    kinds of cases wherein such power should be
    exercised.

    (1) Where the allegations made in the first information
    report or the complaint, even if they are taken
    at their face value and accepted in their entirety
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    do not prima facie constitute any offence or
    make out a case against the accused.

    (2) Where the allegations in the first information report
    and other materials, if any, accompanying the
    FIR do not disclose a cognizable offence,
    justifying an investigation by police officers
    under Section 156 (1) of the Code except under
    an order of a Magistrate within the purview of
    Section 155 (2) of the Code.

    (3) Where the uncontroverted allegations made in the
    FIR or complaint and the evidence collected in
    support of the same do not disclose the
    commission of any offence and make out a case
    against the accused.

    (4) Where, the allegations in the FIR do not constitute
    a cognizable offence but constitute only a
    non-cognizable offence, no investigation is
    permitted by a police officer without an order of a
    Magistrate as contemplated under Section 155 (2)
    of the Code.

    (5)    Where the allegations made in the FIR or
           complaint      are       so   absurd   and   inherently
    

    improbable on the basis of which no prudent
    person can ever reach a just conclusion that there
    is sufficient ground for proceeding against the
    accused.

    (6). Where there is an express legal bar en-grafted in
    any of the provisions of the Code or the Act
    concerned (under which a criminal proceeding is
    instituted) to the institution and continuance of the
    proceedings and/or where there is a specific
    provision in the Code or the Act concerned,
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    providing efficacious redress for the grievance of
    the aggrieved party.

             (7)     Where a criminal proceeding is manifestly
                     attended      with mala fide and/or where the
                     proceeding is         maliciously instituted with an
                     ulterior motive for wreaking vengeance          on the
                     accused and with a view to spite him due to
                     private and personal grudge.
    

    103. We also given a note of caution to the effect that the
    power of quashing a criminal proceeding should be
    exercised very sparingly and with circumspection
    and that too in the rarest of rare cases; that the court
    will not be justified in embarking upon an enquiry as
    to the reliability or genuineness or otherwise of the
    allegations made in the FIR or the complaint and
    that the extraordinary or inherent powers do not
    confer an arbitrary jurisdiction on the court to act
    according to its whim or caprice.”

    13. In case of Madan Razak v State of Bihar and others,

    reported in (2015) 16 SCC 269, Hon’ble Supreme Court while

    considering the ground raised for recording statement of

    witnesses under Section 161 CrPC with delay, has observed

    thus”-

    “10. It is not necessary for us to evaluate the
    statements of witnesses recorded under Section 161
    of the Code of Criminal Procedure. The only
    question to be determined is, whether the
    statements disclosed a prima facie case, leading to
    an offence triable under the provisions of the Indian
    Penal Code
    . We are of the considered view, that it is
    11

    not possible for us to overlook the statements of the
    witnesses recorded, reference to some of which, has
    been indicated in the instant order. The reason for
    the delayed recording of statements is also disclosed
    in the daily diary report. The evaluation of the truth or
    falsity thereof, will be possible only after evidence is
    recorded, in the matter. At the present juncture to
    quash the proceedings initiated against the accused
    by quashing the summoning order dated 6.4.2011 in
    exercise of the power vested in the High Court under
    Section 482 of the Cr.P.C. is clearly not made out.

    12. Since prima facie, commission of offences under
    the Indian Penal Code, are shown to be emerging
    from the statements of witnesses recorded (as is
    apparent from the order dated 6.4.2011 passed by
    the Additional Chief Judicial Magistrate, Rosera), we
    are satisfied, that the impugned order dated
    26.08.2013, passed by the High Court deserves to
    be set aside. The same is accordingly hereby set
    aside.”

    14. In case of Mahendra K.C. v. State of Karnataka and

    another, reported in (2022) 2 SCC 129, Hon’ble Supreme

    Court has observed that the High Court while exercising the

    powers under Section 482 of CrPC (corresponding to Section

    528 of BNSS), does not function as a court of appeal or

    revision. Inherent jurisdiction under the section though wide

    has to be exercised sparingly, carefully and with caution and

    only when such exercise is justified by the tests specifically

    laid down in the section itself. It is further observed that when
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    no offence is disclosed by the report, the court may examine

    the question of fact. When a report is sought to be quashed, it

    is permissible to look into the materials to assess what the

    report has alleged and whether any offence is made out even

    if the allegations are accepted in toto. The High Court, under

    Section 482 CrPC, should normally refrain from giving a

    prima facie decision in a case where the entire facts are

    incomplete and hazy.

    15. In case of Amish Devgan Vs. Union of India, reported in

    (2021) 1 SCC 1, the Hon’ble Supreme Court has held that

    quashing of FIR can only be in exceptional circumstances

    and some of the exceptional circumstances are held to be

    where manifestly there is some legal bar against institution or

    continuation of prosecution; where allegations made even if

    taken at face value do not constitute any offence; allegations

    made do not constitute cognizable offence and allegations

    made are so absurd and improbable that any prudent person

    can ever reach to a conclusion that there is sufficient ground

    for proceeding against accused. In case at hand, apart from

    raising above grounds, counsel for petitioner could not able to

    show at this stage that allegations are so absurd and

    inherently improbable on the basis of which no prudent

    person can ever reach a just conclusion that there is sufficient

    ground for proceeding against petitioner.

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    16. In case of Central Bureau of Investigation vs. Aryan Singh

    and others, reported in (2023) 18 SCC 399, Hon’ble

    Supreme Court has observed that as per cardinal principle of

    law, at the stage of discharge and/or quashing of criminal

    proceedings, while exercising the inherent powers, the Court

    is not required to conduct a mini trial. Relevant portion of the

    said decision is quoted herein below for ready reference:-

    “6. From the impugned common judgment and order
    [Aryan Singh v. CBI, 2022 SCC OnLine P&H 4158]
    passed by the High Court, it appears that the High
    Court has dealt with the proceedings before it, as if,
    the High Court was conducting a mini trial and/or the
    High Court was considering the applications against
    the judgment and order passed by the learned trial
    court on conclusion of trial. As per the cardinal
    principle of law, at the stage of discharge and/or
    quashing of the criminal proceedings, while exercising
    the powers under Section 482 CrPC, the Court is not
    required to conduct the mini trial. The High Court in the
    common impugned judgment and order has observed
    that the charges against the accused are not proved.

    This is not the stage where the
    prosecution/investigating agency is/are required to
    prove the charges. The charges are required to be
    proved during the trial on the basis of the evidence led
    by the prosecution/investigating agency.

    7. Therefore, the High Court has materially erred in
    going in detail in the allegations and the material
    collected during the course of the investigation against
    the accused, at this stage. At the stage of discharge
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    and/or while exercising the powers under Section
    482CrPC, the Court has a very limited jurisdiction and
    is required to consider “whether any sufficient material
    is available to proceed further against the accused for
    which the accused is required to be tried or not.”

    17. From the above quoted decisions of Hon’ble Supreme Court,

    it is clear that at the stage of discharge and/or quashing of

    criminal proceedings, it is not for the High Court to conduct

    mini trial and evaluate evidence. It is only for the trial Court to

    consider. The High Court has to only consider whether there

    is prima facie material or not. In the present case, the

    allegations made in the FIR; the material collected during

    investigation and submitted along with final report, do

    disclose prima facie commission of offences and the matter

    requires adjudication on evidence during trial.

    18. Thus in view of facts and circumstances of present case,

    material available in record and in light of above decisions of

    Hon’ble Supreme Court, we do not find any good ground to

    quash FIR, charge sheet and order dated 13.10.2025 taking

    cognizance on final report submitted by police against

    petitioner.

    19. For the foregoing discussion, we do not find any merit in this

    petition, the same is liable to be and is hereby dismissed.

          Sd/-                                                 Sd/-
    (Parth Prateem Sahu)                                 (Bibhu Datta Guru)
          Judge                                                Judge
    r/-
     



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