In Muskan vs. Ishaan Khan (Sataniya) and Others, the Supreme Court examined the scope of the High Court’s power to quash criminal proceedings under Section 482 CrPC (now Section 528 BNSS). The appellant alleged dowry harassment and cruelty by her husband and in-laws, including a demand of ₹50 lakhs. The Madhya Pradesh High Court quashed the FIR, holding that certain incidents mentioned in the FIR were absent from earlier complaints and appeared to be an afterthought. The Supreme Court set aside the High Court’s order, reiterating that the power under Section 482 CrPC is extraordinary and must be exercised sparingly. The Court held that at the quashing stage, courts cannot assess the credibility, reliability, or inconsistencies of allegations or conduct a “mini trial.” An FIR is not required to be an encyclopaedia of facts, and the test is only whether the allegations, taken at face value, disclose a prima facie cognizable offence. Since the allegations warranted investigation, the quashing was held to be erroneous.