Allahabad High Court Denies Quashing of FIR Against Adnan in Bareilly Protest Case

The Court emphasizes judicious use of extraordinary powers, urging petitioner to seek alternative legal remedies.

In a significant ruling, the Allahabad High Court declined to quash the FIR filed against Adnan in connection with a protest in Bareilly, underscoring the need for restraint in exercising extraordinary powers under Article 226 of the Constitution and Section 482 of the Criminal Procedure Code (CrPC). The protest, which occurred on September 26, 2025, led to violent clashes between police and protestors, resulting in injuries and a disruption of public peace.

The Division Bench, comprising Justices Ajay Bhanot and Garima Prashad, heard the plea from the petitioner, Adnan, who sought to annul the FIR citing a lack of prima facie evidence and the malicious intent behind the allegations. The FIR accused Adnan and others of inciting violence and disrupting law and order during a protest called by Maulana Taukir Raza.

The Court drew upon precedents set by the Supreme Court, particularly in the cases of State of Haryana v. Bhajan Lal and Neeharika Infrastructure Private Limited v. State of Maharashtra, to articulate the stringent parameters for quashing FIRs. It highlighted that such powers should be applied sparingly and only in the "rarest of rare cases" to prevent abuse of legal processes or when there is no cognizable offence.

The Bench emphasized that interim orders, such as staying investigations, should not be issued routinely and must be approached with caution, especially when investigations are ongoing. The petitioner’s counsel, Ansar Ahmad, requested relief from arrest and coercive actions, which the Court declined, reinforcing the ongoing nature of the investigation.

Ultimately, the Court did not entertain the plea for quashing the FIR but granted the petitioner the liberty to pursue other legal remedies. The judgment underscores the judiciary's cautious approach in intervening with ongoing investigations and reinforces the legal principle that not all grievances should lead to the quashing of criminal proceedings.

Bottom Line:

Quashing of FIR - Parameters for exercise of powers under Article 226 of the Constitution or Section 482 CrPC - Extraordinary power to quash a criminal proceeding should be exercised sparingly and in rarest of rare cases to prevent abuse of the process of law or to secure the ends of justice.

Statutory provision(s): Article 226 of the Constitution of India, Section 482 of the Criminal Procedure Code, 1973, Bharatiya Nyaya Sanhita (B.N.S.) sections 191(2), 191(3), 190, 124(2), 121, 125, 352, 351(3), 109, 299, 223, Section 7 of the Criminal Law Amendment Act, 1932.

Adnan v. State of U.P., (Allahabad)(DB) : Law Finder Doc Id # 2810765