In Brief
M.L. Wadhawan challenged a High Court order refusing to quash defamation proceedings under Section 499 of the Indian Penal Code against him. The Supreme Court found that Wadhawan's written submissions before the adjudicating authority were merely reiterations of statements recorded under Section 164 CrPC, statements in a show cause notice, and counter affidavits filed in court. The Court held that prima facie no defamation case was made out, as the essential ingredients of the offence were not satisfied. Accordingly, the appeal was allowed and the criminal proceedings were quashed."
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