हरियाणा राज्य बनाम भजन लाल
| Citation | 1992 Supp (1) SCC 335 |
| Court | Supreme Court of India |
| Date | 21 November 1990 |
| Year | 1992 |
| Bench | M.N. Venkatachaliah, S. Mohan JJ. |
| Acts/Articles | CrPC Section 482, Article 226, Article 227 |
| Category | Criminal 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.
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.
The Court laid down seven exhaustive categories where FIR/criminal proceedings can be quashed under Section 482 CrPC:
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.
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Read AnalysisThis 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).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.