The Supreme Court criticised contradictory High Court rulings in a dowry case, warning they harm public trust. It stressed that consistency in verdicts is key to a responsible and credible judiciary.
New Delhi: The Supreme Court of India recently delivered a strong message on judicial consistency while hearing a matrimonial case. The apex court criticised how two different single benches of the Karnataka High Court gave opposite decisions in the same matter, which led to confusion and shook the public’s faith in the justice system.
The case involved a woman who filed a criminal complaint against her husband and in-laws, accusing them of assault, dowry harassment, and ill-treatment. She alleged that her husband had an affair with another woman and that both her husband and in-laws abused her verbally, mentally, and physically.
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She also claimed they demanded a dowry of ₹2 lakh. Due to the continuous harassment, she eventually left her matrimonial home and moved in with her parents. A First Information Report (FIR) was registered against the husband and his family.
Later, both the husband and his in-laws went to the High Court asking to cancel the FIR. Two different judges of the Karnataka High Court heard the matter. One judge refused to cancel the proceedings against the in-laws, noting that the medical or wound certificate showed the woman had suffered injuries.
But another judge quashed the FIR against the husband, saying the medical certificate did not match the claims in the complaint and that the injuries could not have been caused by a blunt weapon.
The Supreme Court bench, comprising Justices P. S. Narasimha and Joymalya Bagchi, expressed serious concern over these conflicting orders.
“The case at hand portrays a disturbing picture. While one judge refused to quash proceeding against the in-laws, inter alia, observing the wound certificate demonstrates the appellant was assaulted and suffered simple injuries, another judge by the impugned order quashed the proceeding against respondent husband holding the medical certificate was not consistent with the allegations in the complaint, i.e., the wound certificate does not show the injuries were caused by a blunt weapon.”
Justice Joymalya Bagchi, who wrote the judgment, criticized the High Court judge who quashed the case against the husband.
“Having perused the impugned judgment, we are of the view the judge erred in law by embarking upon an enquiry with regard to the credibility or otherwise of the allegations in the FIR/chargesheet.”
The Supreme Court pointed out that the High Court judge wrongly tried to assess the truthfulness of the complaint by comparing it with the medical report.
“The judge compared the nature of assault described in the FIR in relation to the wound certificate and held the allegations to be untrue.”
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The apex court held that the High Court judge acted like a trial court at the initial stage of the case, which was not allowed under the law.
“In the process, the judge performed a mini-trial to quash the proceeding an exercise impermissible in law.”
The Supreme Court also questioned why the earlier order from the other High Court judge (who did not quash the case against the in-laws) was not mentioned in the second judge’s order.
“It was incumbent on the judge while quashing the proceeding against the respondent husband to refer to the earlier decision of the co-ordinate bench and distinguish the reasons therein to arrive at a different conclusion. Failure to do so infracts judicial propriety and discipline.”
According to the Supreme Court, consistency in legal decisions is vital for maintaining the reputation of the judiciary.
“Inconsistent decisions coming out from different benches shake public trust and reduce litigation to a punter’s game. It gives rise to various insidious sharp practices like forum shopping spoiling the clear stream of justice.”
The bench further said that the High Court judge was wrong in concluding that the case was false or an abuse of the legal process just because the matrimonial case was still pending.
“The high court judge misdirected himself in holding that the proceeding was malicious and an abuse of the process of the court as the matter was pending in the matrimonial court.”
The Supreme Court noted that many criminal cases, especially those involving cruelty or harassment, arise out of troubled marriages.
“Offences involving cruelty on wife would invariably arise out of matrimonial disputes.”
The top court concluded that the High Court’s order to cancel the FIR against the husband was biased and had no legal basis.
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“The impugned order suffered from the vice of judicial caprice and deserved to be set aside.”
It also clarified that just because a matrimonial case is ongoing, it does not mean that the criminal complaint is fake, especially when supported by medical evidence and witnesses.
“The pendency of the matrimonial case couldn’t per se lead to an inference that institution of criminal proceeding alleging assault supported by medical evidence and independent witness was a product of malice and abuse of the court.”
The bench also mentioned that there was no evidence to show that the woman had not been injured.
“It was nobody’s case that no injury was noted in the wound certificate thereby rendering the allegation of assault patently absurd or inherently improbable.”
Finally, the Supreme Court strongly rejected the High Court’s decision to assess the credibility of the complaint at an early stage.
“In this backdrop, it was unwarranted for the judge to embark on a mini trial to weigh the ocular version vis-à-vis medical evidence and quash the proceeding. Whether the ocular evidence is fully incompatible with medical evidence is a matter of trial and cannot be a ground to terminate prosecution at the initial stage.”
This judgment from the Supreme Court sets a clear precedent that inconsistent rulings by different benches can lead to confusion, damage public faith in the legal system, and should be avoided to maintain the discipline and propriety of the judiciary.
Advocates Rudrali Patil, Shaantanu Devansh, Suhas Hosamani, Rushika Patil, Sabeel Ahmed and Anshuman represented the appellant wife.
Advocate DL Chidananda represented the State.
Senior Advocate Anand Sanjay M Nuli with advocates Abhishek Kanyalur, Suraj Kaushik Nanda Kumar K B, Akhila Wali and Akash Kukreja of Nuli & Nuli represented the respondent-husband.
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