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2026 Supreme(Online)(Kar) 20160

THE HIGH COURT OF KARNATAKA
M.Nagaprasanna, J
.... – Appellant
Versus
State of Karnataka – Respondent
CRL.P No. 2236 of 2025



Advocates:
For the Appellants/Petitioners: Tejas N.
For the Respondents: Channappa Earappa, Kemparaju

Criminal proceedings against an individual should be quashed when the complaint lacks essential ingredients for offences like cheating or criminal intimidation and fails to demonstrate the individual's specific involvement in the core illegal acts, thereby preventing an abuse of legal process.

Headnote:(A) Indian Penal Code, 1860 - Sections 504, 506, 420 and 34 - Quashing of FIR - Petitioner alleged to be involved in cheating and criminal intimidation - Investigation reveals transactions were between complainant and other accused - No ingredients of cheating (S.415 IPC) or intentional insult (S.504 IPC) or criminal intimidation (S.506 IPC) made out against petitioner - Mere abusive language without specific details does not constitute offence under S.504 IPC - Petitioner's involvement absent in the core dispute - Continuation of proceedings would be an abuse of process of law.

Facts of the case:
The petitioner is the daughter of the primary accused in a financial dispute involving investments in Telugu films and gold ornaments. The complainant alleged that the petitioner verbally abused and threatened her. The petitioner sought quashing of the FIR registered for offences under Sections 504, 506, 420 and 34 of the IPC, asserting her lack of involvement in the underlying business transactions between the complainant and other accused parties.

Findings of Court:
The court observed that the core dispute was exclusively between the complainant and others. It held that the complaint lacked specific details regarding the alleged threats or abuses to sustain charges under Sections 504 and 506 IPC, and failed to establish any elements of cheating (S. 420 IPC) against the petitioner.

Issues: Whether criminal proceedings can be sustained against an individual solely on vague allegations of verbal abuse and threats where no nexus to the primary criminal acts is established.

Ratio Decidendi: Mere allegation of verbal abuse without detailing the specific words used does not satisfy the ingredients of intentional insult; failure to establish fraudulent intention or inducement to deliver property precludes prosecution for cheating; dragging uninvolved family members into criminal proceedings constitutes an abuse of process.

Result: Petition allowed; proceedings quashed against the petitioner.

Table of Content
1. summary of facts and contentions regarding the petitioner's lack of role. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7)
2. analysis of ingredients required for the offence of cheating (section 420 ipc). (Para 8)
3. analysis of ingredients required for intentional insult and criminal intimidation (sections 504 and 506 ipc). (Para 9)
4. court's decision to quash the proceedings due to lack of ingredients against the petitioner. (Para 10 , 11)

THIS CRL.P IS FILED U/S 482 CR.PC (FILED U/S 528 BNSS) BY THE ADVOCATE FOR THE PETITIONER PRAYING THAT THIS HONOURABLE COURT MAY BE PLEASED TO QUASH THE FIR IN CR.NO.2/2025 OF BYAPPANAHALLI POLICE STATION, BENGLAURU, WHICH IS PENDING ON THE FILE OF THE HONBLE 10TH ADDL. CMM, MAYO HALL UNIT, BENGALURU FOR THE OFFENCE P/U/S 506, 504, 420 AND 34 OF IPC AND THE CONSEQUENT INVESTIGATION AS AN ABUSE OF PROCESS OF LAW.

THIS PETITION, COMING ON FOR ADMISSION, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA

ORAL ORDER

The petitioner is before this Court calling in question the registration of a crime in Crime No.2/2025 registered for the offences punishable under Sections 506, 504, 420 and 34 of the IPC.

2. Heard the learned counsel Sri. Tejas N appearing for the petitioner, learned HCGP Sri. Channappa Earappa appearing for respondent No.1 and learned counsel Sri. Kemparaju appearing for respondent No.2.

3. Facts, in brief, germane are as follows:

The petitioner is accused No.3 in the subject crime and the 2nd respondent is the complainant. Respondent No.2 and accused No.1 have a transaction. The transaction between the two goes sore and a complaint comes to be registered by the 2nd respondent, which becomes subject matter of the impugned crime for the aforesaid offences. The registration of the crime is what has driven the petitioner to this Court in the subject petition.

4. The learned counsel appearing for the petitioner submits that the allegations are against accused Nos.1 and 2, who have certain chipped transaction with the complainant. The petitioner being the daughter of accused No. 1 would not mean that she should be dragged into the web of proceedings.

5. Learned counsel appearing for respondent No.2 would though submit that the matter would require investigation in the least, would admit that there is no role of accused No. 3, while the transaction is entirely between the accused Nos. 1 and 2 and the complainant.

6. I have given my anxious consideration to the submissions made by the respective learned counsel and have perused the material on record.

7. The issue now is reduced to a narrow compass as to whether the complainant would make up any case against the petitioner. I deem it appropriate to notice the complaint. It reads as follows:

“03-01-2025

To,

The Police Inspector

Byppanahalli Police Station,

Bengaluru.

Subject: Complaint Against Mrs. Prapulla, Mr. Manjunath Reddy, XXXX, Mrs. Meenakshi B.V., Mr. Mani, and Mr. Rajesh for Cheating with an intention from the beginning.

Respected Sir,

I, Mrs.Shakuntala Murthy, w/o Krishna Murthy residing atthe below mentioned address along with my daughter Mrs.Bhargaviwould lodge this formal complaint againstMrs. Prapulla, wife of Mr. Manjunath Reddy, Mr. Manjunath Reddy, XXXX d/o Mr. Manjunath Reddy, Mrs. Meenakshi B.V., Mr. Mani, and Mr. Rajesh for cheating and obtaining various gold ornaments and cash from me and my daughter Mrs. Bhargavi, my Daughter-in-laws Mrs, Mamatha and Mrs. Neetha and under false pretences and intentionally cheating us.All transactions took place at sadanandnagar, NGEF.

Since 2015, Mrs. Prapulla has repeatedly approached me under the pretext of various business and investment opportunities(along with her three brothers Mr. Venu Gopal Reddy,Janaradhan Reddy, Bhoopal Reddy). She initially gained my trust by presenting herself as a successful businesswoman involved in multiple ventures.Over time, she convinced me to lend her substantial amounts of money and gold ornaments,promising that these w

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