In Brief
M.L. Wadhawan, accused of defamation under Section 499 of the Indian Penal Code, challenged the High Court's order refusing to quash the criminal proceedings against him. His prosecution was based on written submissions he filed before an adjudicating authority. The Supreme Court examined the submissions and found them to be largely repetitions of statements recorded under Section 164 CrPC and statements in show cause notices. The Court held that no prima facie case of defamation was made out, as the essential ingredients of the offence were not satisfied. The appeal was allowed and the criminal proceedings were quashed.
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