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Supreme Court of India 2025-04-29 allowed

Renuka vs State of Karnataka and Anr

Bench: 2 — Pamidighantam Sri Narasimha, Joymalya Bagchi

In Brief

An appellant-wife filed a criminal complaint against her husband and in-laws for physical harassment, dowry demands, and assault with chilli powder and stones. While one High Court judge refused to quash proceedings against the co-accused, another judge quashed the case against the husband, finding the injury evidence inconsistent with assault allegations. The Supreme Court held that judges cannot conduct mini trials by comparing medical and ocular evidence to quash proceedings; that is the trial court's role. Since the wife's injuries and an independent witness's account supported the allegations, the case could not be quashed. The Court also emphasized that inconsistent decisions from co-ordinate benches without reasoned distinction violate judicial integrity. The appeal was allowed and proceedings against the husband were revived.

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Criminal Procedure Inherent Jurisdiction Quashing of Proceedings Dowry Harassment Domestic Violence Section 498-A IPC Assault Criminal Conspiracy Judicial Propriety Consistency in Judgment

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