Mini Trial | The Last Word

R.P. Kapur v. State of Punjab, 1960 SCC OnLine SC 21 enumerated category of cases where inherent powers may be invoked to quash a criminal proceeding. But, “High Court would not embark upon an enquiry as to whether evidence in question is reliable or not. Ordinarily it would not be open to any party to invoke High Court’s inherent jurisdiction and contend, on a reasonable appreciation of evidence, accusation made would not be sustained…”

This view has been consistently followed and, in a catena of cases, Court has repeatedly forbidden High Courts from embarking on a ‘mini trial’ in exercise of its inherent jurisdiction to quash proceedings.

See, Neeharika Infrastructure Private Limited v. State of Maharashtra, 2021 SCC OnLine SC 315 (Paragraph 10.7); State of Odisha v. Pratima Mohanty, 2021 SCC OnLine SC 1222 (Paragraph 8.2); State of Uttar Pradesh v. Akhil Sharda, 2022 SCC OnLine SC 820 (Paragraph 18); State v. M. Maridoss, 2023 SCC OnLine SC 47 (Paragraph 7); Central Bureau of Investigation v. Aryan Singh, 2023 SCC OnLine SC 379 (Paragraph 6); Dharambeer Kumar Singh v. State of Jharkhand, 2024 SCC OnLine SC 1894 (Paragraph 17); Ranjeet Mittal v. State of Madhya Pradesh, 2024 SCC OnLine SC 2926 (Paragraph 19).

– Hon’ble Justice Joymalya Bagchi, Renuka v. State of Karnataka, [Diary No. 55944 of 2024].