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Issues:
1. Quashing of FIR and proceedings under Section 482 Cr.P.C. 2. High Court's jurisdiction in dealing with charges framed by Magistrate under Sections 239 and 240 Cr.P.C. 3. Consideration of documents in revisional jurisdiction for quashing charges under Section 240 Cr.P.C. 4. Admissibility of affidavit evidence in determining commission of an offense at the charge-framing stage. Analysis: The Supreme Court addressed the issue of quashing the FIR and proceedings under Section 482 Cr.P.C. The appellant had lodged an FIR alleging offenses under Sections 406 and 498-A of the Indian Penal Code against her husband's family. The High Court quashed the proceeding, including charges framed against the accused, at a stage when the Magistrate had already taken cognizance and framed charges. The Supreme Court criticized the High Court's approach, emphasizing that once charges are framed under Section 240 Cr.P.C., the High Court should not rely on documents beyond those referred to in Sections 239 and 240 Cr.P.C. The Court highlighted that the High Court's inherent jurisdiction under Section 482 Cr.P.C. should only be invoked in rare cases with compelling reasons. The Supreme Court allowed the appeals, set aside the impugned order, and remanded the matter to the High Court for proper disposal. Regarding the High Court's jurisdiction in dealing with charges framed by the Magistrate under Sections 239 and 240 Cr.P.C., the Supreme Court clarified that the Magistrate, upon framing charges, must follow the procedure outlined in these sections. The accused can challenge the charges through revisional jurisdiction, but the High Court should limit its review to the documents referred to in Sections 239 and 240 Cr.P.C. The Court emphasized that the High Court cannot delve into the merits of the case at the charge-framing stage and should not base its decision on affidavit evidence. The Supreme Court discussed the consideration of documents in revisional jurisdiction for quashing charges under Section 240 Cr.P.C. The Court reiterated that the High Court's review should be restricted to the documents specified in Sections 239 and 240 Cr.P.C. Exceptionally, the High Court may consider additional documents in rare cases with strong justifications. The Court emphasized the importance of relying only on legally admissible and unimpeachable evidence during such reviews. Lastly, the issue of admissibility of affidavit evidence in determining the commission of an offense at the charge-framing stage was addressed. The Supreme Court emphasized that findings regarding the commission of an offense cannot be based solely on affidavit evidence. The Court stated that the trial court, not the High Court, is responsible for evaluating the merits of the case. Therefore, the High Court should not usurp the trial court's functions and should refrain from deciding the case's merits based on affidavit evidence.
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