STATE OF HARYANA v. BHAJAN LAL (1992 SUPP (1) SCC 335): GUIDELINES FOR QUASHING OF FIR UNDER SECTION 482 OF THE CODE OF CRIMINAL PROCEDURE, 1973

The case of State of Haryana v. Bhajan Lal is a landmark judgment of the Supreme Court of India that established important principles governing the exercise of inherent powers of High Courts under Section 482 of the Code of Criminal Procedure, 1973, and Article 226 of the Constitution. The judgment addresses the balance between preventing abuse of the criminal process and ensuring that legitimate investigations are not prematurely interrupted. The Supreme Court held that quashing of FIRs should be exercised sparingly and only in exceptional circumstances where continuation of proceedings would amount to misuse of legal process. The Court laid down seven illustrative categories where criminal proceedings may be quashed, including cases where allegations do not disclose any offence, proceedings are maliciously instituted, or where continuation would be unjust. The decision continues to serve as a guiding precedent for courts while dealing with petitions seeking quashing of FIRs, emphasizing judicial restraint, protection of individual liberty, and preservation of fair investigative processes.