Whether the refusal to proceed with the criminal complaint was justified because the alleged facts did not constitute a criminal offense.
Yes. The facts as presented did not clearly amount to a criminal offense and could at most give rise to administrative remedies.
A refusal to proceed on the merits is justified only when conviction can be excluded from the outset with certainty. Here, the alleged conduct was not criminally qualifying on its face and was instead potentially amenable to prison-administration complaint or appeal procedures.