The applicant, Rashmikant Jyantilal Patel, filed a petition under Section 482 of the CrPC before the Gujarat High Court seeking to quash an FIR registered at Ellisbridge Police Station, Ahmedabad, for offences under the Gujarat Prohibition Act, relating to possession of 161 bottles of Indian Made Foreign Liquor without a pass or permit. The applicant was not named in the original FIR and was arraigned as an accused solely on the basis of a co-accused's statement, with no independent recovery, call records, or other corroborating material linking him to the crime. The court noted that the charge-sheet contained no direct evidence of any overt act by the applicant, and relied on the Supreme Court's ruling in P. Krishna Mohan Reddy v. State of Andhra Pradesh (2025) to hold that a confessional or inculpatory statement of a co-accused recorded under Section 161 CrPC is inadmissible against another co-accused by virtue of Sections 25 and 26 of the Indian Evidence Act, and that an exculpatory statement of a co-accused implicating another accused also cannot be relied upon. On this basis, the court found that continuing the prosecution against the applicant would be an abuse of process of law.