Punjab & Haryana High Court, Chandigarh
Citation1992 Supp (1) SCC 335
CourtSupreme Court of India
Date21 November 1990
Year1992
BenchM.N. Venkatachaliah, S. Mohan JJ.
Acts/ArticlesCrPC Section 482, Article 226, Article 227
CategoryCriminal Law, Haryana-Specific

Key Principle Established

Seven categories of cases where High Court can exercise power under Section 482 CrPC (now Section 528 BNSS) to quash FIR/criminal proceedings. The most cited judgment on quashing.

Brief Facts

Bhajan Lal, former Chief Minister of Haryana, was accused in a case registered at Chandigarh. The State challenged the quashing of the FIR by the High Court.

Ratio Decidendi

The Court laid down seven exhaustive categories where FIR/criminal proceedings can be quashed under Section 482 CrPC:

  • Category 1: Allegations do not prima facie constitute any offence
  • Category 2: Allegations are so absurd and inherently improbable that no prudent person would reach such a conclusion
  • Category 3: Clear legal bar to prosecution (e.g., limitation, absence of sanction)
  • Category 4: Allegations constitute a civil wrong only, not a criminal offence
  • Category 5: Criminal proceedings are manifestly attended with mala fide and instituted with ulterior motive
  • Category 6: FIR does not disclose a cognizable offence
  • Category 7: Where there is an express legal bar to institution/continuance of proceedings

Impact & Significance

This Haryana-origin judgment is the most cited authority on quashing of FIRs in India. Every application under Section 482 CrPC (now Section 528 BNSS) relies on the Bhajan Lal categories. It is cited in literally thousands of cases annually across all High Courts and the Supreme Court.

Tags & Related Topics

Criminal Law Haryana-Specific CrPC Section 482 Article 226 Article 227
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Disclaimer

This judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).

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