The Supreme Court of India, in Marippan & Anr. v. State Represented by the Inspector of Police & Anr., has quashed criminal proceedings against two appellants, holding that forcing them to stand trial in the absence of any substantive evidence would amount to an “abuse of the process of the Court.” The Bench of Justice Ahsanuddin Amanullah and Justice K. V. Viswanathan emphasized that individuals should not be dragged into criminal trials without clear evidence of wrongdoing.
Background of the Case
The case stems from allegations made by a woman who claimed that she was in a relationship with the son of the appellants. According to the complaint, she engaged in physical relations with him under the assurance that he would marry her. The complainant alleged that she was later abandoned after the man’s parents arranged his marriage with another woman. She further contended that the appellants had assured her of their acceptance, which led her to believe that marriage was inevitable.
Following the complaint, a chargesheet was filed against the appellants under Sections 417 (cheating) and 109 (abetment) of the Indian Penal Code (IPC). The appellants moved the Madras High Court (Madurai Bench) under Section 482 of the Criminal Procedure Code (CrPC) seeking quashing of the charges, but the High Court rejected their plea. This prompted them to approach the Supreme Court.
Key Legal Issues
1. Did the appellants (parents) make any direct or indirect misrepresentation to the complainant, leading to the offense of cheating?
2. Whether the parents’ alleged assurance amounted to abetment of cheating under IPC?
3. Should the trial court proceed against individuals against whom no direct allegations of wrongdoing exist?
Supreme Court’s Observations
The Supreme Court scrutinized the complaint and found that there was no specific allegation against the appellants regarding any deliberate misrepresentation or instigation of their son’s actions. The Court noted:
“Even otherwise, from what is alleged in the complaint itself, we do not find that there is any act or conduct on the part of the appellants which can be termed to be illegal per se, much less criminal in nature. No ingredients of any offense under the IPC appear to be forthcoming.”
The Court further highlighted that the complainant, aged 29 years and a postgraduate professional, had the capacity to make independent decisions. It ruled that the facts of the case did not suggest that the complainant was induced into an intimate relationship solely based on the alleged assurance by the appellants.
Citing Vishnu Kumar Shukla v. State of Uttar Pradesh (2023) 15 SCC 502, the Bench reaffirmed the principle that courts should quash frivolous proceedings where no strong suspicion exists to hold the accused liable. The ruling stated:
“It would be unjustified to make the appellants face a full-fledged criminal trial in this backdrop. The protection against vexatious and unwarranted criminal prosecution is a duty cast on the High Courts.”
High Court’s Controversial Observation Expunged
While delivering its ruling, the Supreme Court also expressed disapproval of an objectionable observation made by the High Court, which stated:
“If this petition is allowed, the petitioners’ son will spoil women of marriageable age in the same manner.”
The Apex Court noted that the son of the appellants was not before the High Court and was not given an opportunity to present his defense. It termed this remark as unwarranted and directed its deletion from the High Court’s records, following the precedent set in Anu Kumar v. State (UT Administration), 2021 SCC OnLine SC 3454.
Supreme Court’s Verdict
The Supreme Court quashed the criminal proceedings against the appellants in P.R.C. No.16/2022 and discharged them from any liabilities related to their bail bonds and sureties. The ruling, however, clarified that its decision would not prejudice the pending case against the appellants’ son.
The Court ordered that a copy of the judgment be sent to the Registrar (Judicial) of the Madurai Bench, Madras High Court, for necessary compliance.
