MUNICIPAL CORPORATION OF DELHI vs RAM KISHAN ROHTAGI AND OTHERS

The Supreme Court held that the High Court has the inherent power under Section 482 of the Code of Criminal Procedure, 1973 to quash an order summoning accused if the allegations in the complaint do not constitute an offence. The Court clarified that Section 397(2) does not limit this inherent power, which is independent and can be exercised to prevent grave injustice. The Court upheld the High Court's decision to quash proceedings against the Directors but allowed the appeal regarding the Manager, indicating a distinction in the applicability of criminal responsibility based on the allegations made.