Criminal Law – Quashing of FIR - Matrimonial Dispute – General Allegations Against In-Laws – Proceedings Quashed in Part - Petitioners challenged FIR under Sections 498A, 504, 506 IPC – Allegations against petitioner No.4 (Surinder Kaur) were found vague and lacking specific instances of cruelty or provocation – Held: Prosecution against her is abuse of process – FIR and proceedings quashed qua petitioner No.4 [Paras 24–25].

Cruelty – Specific Allegations Against Husband and Sister-in-Law – Proceedings to Continue - Allegations that petitioner No.1 (husband) and petitioner No.3 (sister-in-law) compelled complainant to conceive, denied food and support during pregnancy, and subjected her to physical abuse – Held: Sufficiently specific to warrant trial – Petition to quash FIR against them rejected [Paras 22–23].

Intentional Insult – Ingredients of Section 504 IPC – Not Attracted for Mere Abuse - Citing Vikram Johar and Fiona Shrikhande, Court held that mere abuse without intent to provoke breach of peace does not fulfill requirements of Section 504 IPC – No material indicating intentional insult by petitioner No.4 – FIR quashed to this extent [Paras 24–25].

False Implication – Use of Omnibus Allegations in Matrimonial Disputes – Legal Caution Issued - Court reiterated that vague, generalized complaints against all in-laws must be scrutinized – Referred to Supreme Court precedents in Kahkashan Kausar, Neelu Chopra, Achin Gupta, etc. – Held: No blanket criminalisation of family members without clear roles [Paras 14–20].

Final Decision – Petition Allowed in Part – FIR Quashed Against Petitioner No.4 - Proceedings against petitioner Nos. 1 and 3 to continue – Petition partly allowed under Section 482 CrPC [Para 25].
 

Criminal Law - Maintainability of Complaint – Complaint by Mother-in-law under DV Act – Legally Permissible - The applicants argued that a mother-in-law is not competent to file an application under Section 12 of the Domestic Violence Act – Held: An aggrieved woman includes any woman in a domestic relationship, and a mother-in-law can file complaint if she has lived in a shared household and suffered domestic violence – Argument of non-maintainability rejected [Paras 9–12].

Prima Facie Satisfaction – Validity of Summoning Order – Summons Upheld - The summoning order dated 13.09.2024 was based on material available on record and the complaint filed by the mother-in-law – Held: Trial court rightly issued process after recording satisfaction of a prima facie case – No interference warranted under Section 482 Cr.P.C. [Paras 7–8, 13].

Defensive Pleas at Preliminary Stage – Scope of 482 Cr.P.C. – Relief Denied - Applicants argued that the complaint was a counterblast to an FIR filed under Sections 498A, 323, 504, 506 IPC and Dowry Prohibition Act – Held: Defensive arguments relating to counter-allegations and pending Section 125 Cr.P.C. application are matters for trial – Such defences do not warrant quashing under Section 482 Cr.P.C. [Paras 5–6, 8].

Interpretation – Beneficial Legislation – Liberal Interpretation of Domestic Violence Act - The Court emphasised the need to interpret the Domestic Violence Act as a beneficial statute – Held: Definitions under the Act are to be liberally construed to advance its object of protecting women from violence in domestic settings [Paras 10–11].

Civil Law - Specific Performance – Execution and Validity of Agreements – Agreement Upheld – Plaintiff established execution of two agreements dated 17.02.2001 (Ex.P2 and Ex.P4) – Court held both agreements genuine, proving advance payment of Rs. 25,00,000, including a cash component of Rs. 22,30,000 – Defendant’s denial disbelieved due to signature admissions and consistent evidence – Held: Execution and terms of sale agreement proved [Paras 6.1–6.5]. 
 
Doctrine of Novation – Alleged Substitution of Agreement – No Novation Found – Defendants contended that Ex.P4 substituted Ex.P2 with reduced price – Court found Ex.P4 was created for stamp duty and tax avoidance without rescinding Ex.P2 – Held: Both agreements co-exist and must be read together – No novation established [Paras 7.1–7.3]. 
 
Obligations of Parties – Vendor Obligated to Obtain Land Conversion – Vendor Failed – Under agreement terms, vendor was required to secure conversion to non-agricultural use and IT clearances – Court held vendor failed to fulfill these essential obligations, while plaintiff demonstrated willingness and financial capacity – Held: Vendor breached primary obligations under contract [Paras 8–9.3]. 
 
Amendment of Written Statement – Rejection Justified – Trial court rejected Defendant 1’s belated application to amend WS to deny cheque and agreement – High Court upheld the order, finding the amendment lacked bonafide and amounted to retraction of earlier admissions – Held: No error in rejecting amendment [Paras 11.1–11.6]. 
 
Discretion for Specific Performance – Conduct of Defendant and Equity – Decree Granted – Despite amendment to Specific Relief Act being prospective, Court exercised discretion to grant specific performance – Defendant sold property during pendency of suit in violation of court’s status quo order – Held: Plaintiff entitled to specific performance due to vendor’s fraudulent and culpable conduct [Paras 12–13.2]. 
 
Doctrine of Lis Pendens – Transfer Pendente Lite Void Against Plaintiff – 2nd Defendant’s Title Not Protected – Court held that sale by Defendant 1 to Defendant 2 during suit was in violation of status quo order – 2nd Defendant, though a purchaser, could not retain the property against prior agreement – Held: Transfer void under Section 52 TPA – Plaintiff’s claim prevails [Paras 14.1–14.3]. 
 
 

Criminal Law - Quashing of Criminal Proceedings – Section 482, Code of Criminal Procedure, 1973 - Allegations under IPC and SC/ST Act – Quashing Partially Allowed – The applicants sought to quash the FIR and proceedings initiated under sections of IPC and the SC/ST Act arising out of alleged cruelty and caste-based abuse following an inter-caste marriage – The Court observed that applicant No.4 (sister-in-law) was only alleged to have made general statements about divorce and remarriage, and no specific caste-based abuse or cruelty was attributed to her – Held: Allegations against applicant No.4 do not establish cruelty or attract provisions of the SC/ST Act; proceedings against her quashed to prevent abuse of process – Application withdrawn in respect of applicant Nos.1 to 3 [Paras 13-15].

Decision: The application was allowed in part – Proceedings in Special Case No.273 of 2023 quashed only with respect to Applicant No.4 (Apurva Nitinchandra Patil) – Application of Applicant Nos.1 to 3 was dismissed as withdrawn.

Eviction Petition – NRI Landlord’s Right – Section 13-B of the 1949 Act – Eviction Upheld – An eviction petition was filed by an NRI landlord invoking Section 13-B for possession of premises required for personal use – The tenant sought condonation of delay in filing leave to defend, claiming lack of notice – Held: The NRI landlord had a statutory right under Section 13-B, subject to a five-year ownership and single-use limitation – Procedural safeguards under Section 18-A do not allow condonation of delay under Limitation Act – Delay could not be condoned – Eviction maintained [Paras 2, 4, 12-14].

Jurisdiction – Rent Controller Cannot Invoke Section 5 of Limitation Act – Special Statute Prevails – Court distinguished prior judgments permitting liberal construction – Reiterated that provisions under Sections 13-B and 18-A are self-contained and exclude application of general law of limitation – Held: In absence of valid service or exceptional cause, delay cannot be condoned [Paras 10–11].

Summons – Validity and Service – No Justification for Delay – Tenant claimed non-service of summons and miscommunication with counsel – Court found tenant was aware and represented, but failed to act within statutory time – Held: No sufficient cause for delay; statutory protection cannot be diluted on technical pleas [Para 6].

Decision – Revision Petition Dismissed – Eviction Order Sustained – High Court upheld Rent Controller’s order refusing condonation of delay and eviction of tenant – Held: Revision petition devoid of merit; dismissed with confirmation of vacant possession order in landlord’s favour [Paras 7–9].
 

Civil Law – Injunction - Right to Privacy – Unauthorized Recording in Private Space – Consent Required – Partial Relief Granted – Plaintiff had consented to being recorded during the live debate but not after she exited the debate frame – Court held that the recording of the additional 18 seconds after Plaintiff withdrew was done without consent, violating her privacy under Article 21 – Video segment barred from public circulation – Interim relief granted [Paras 19-20].  

Defamation – False Attribution in Quote Tweet – Partially Defamatory – Quote Tweet by Defendant No. 1 accusing Plaintiff of “chucking the mic” and “throwing out” cameraman held untrue and lacking factual basis – Such assertions not protected by the defence of truth and must be deleted – However, statement about “abusing” the cameraman held substantially true – Partial protection granted under fair comment [Paras 22.4-22.7].

 Doctrine of Clean Hands – Suppression of Plaintiff’s Tweets – Cost Imposed – Plaintiff failed to disclose two tweets forming part of the conversation thread relevant to the case – Court held this to be suppression of material facts – Plaintiff directed to pay Rs. 25,000/- in costs to the Delhi High Court Bar Clerks’ Association [Paras 14, 28].  

Doctored Video Allegation – Not Substantiated – Plaintiff’s claim that the impugned video was doctored found to be unsubstantiated – Local Commissioner report found no conclusive evidence of tampering – Allegation held to be an afterthought [Para 24].  

Norms of Journalistic Conduct – Personal Comments Not Covered – Quote Tweet not a journalistic article but a personal comment of Defendant No. 1 – Norms of journalistic conduct not applicable to Defendant No. 1, but applicable to Defendants 6–10 who reposted and amplified the video without verification – Take-down orders confirmed against those defendants [Paras

23.2-23.4].

 Decision – Interim Injunction Partially Allowed – Video with post-debate 18second segment barred – Defendants 1 and 2 restrained from publishing or circulating impugned segment – Defendants 6 to 10 also directed to remove same – Some parts of tweet text to be retained while defamatory phrases to be taken down – Suit to proceed on merits [Paras 25-30].

Civil Law - Partition Suit – Ancestral Property -  Daughters and Their Heirs Entitled to Share – Ancestral Property – Decree Affirmed - Trial court held that plaintiffs (daughters and heirs of Late Sayanna) were entitled to 1/6th share in the ancestral property despite prior alienation to defendant – High Court upheld decree, applying amended Section 6 of Hindu Succession Act giving coparcenary rights to daughters [Paras 8–11, 17–18].

Applicability of 2005 Amendment – Retrospective Benefit to Daughters – Vineeta Sharma Case Applied - Despite daughter Yadamma predeceasing father Sayanna, Court held that her children (plaintiffs) were entitled to share under amended law—Alienation in 2008 not protected as it was post-2005 amendment—Sale without daughters' consent invalid for their share [Paras 13, 17–18].

Mutation and Possession – Not Conclusive of Title – No Registered Partition Proven - Appellant argued partition and mutation among male heirs occurred in 1989—Court held mere revenue mutation or oral arrangement cannot override inheritance rights without registered partition deed—Constructive possession held in favour of all Class-I heirs [Paras 6–7, 18].

Court Fee – Section 34(2) – Constructive Possession Sufficient – Objection Overruled - Though appellant argued plaintiffs not in possession and court fee insufficient, Court held that in cases of joint family property, co-owners are deemed in constructive possession—Court fee paid correctly [Paras 9, 12].

Decision – Appeal Dismissed – Decree for Partition and Allotment of 1/6th Share Each to Plaintiffs and Legal Heirs Affirmed – Sale in Favour of Defendant No.6 Not Binding Beyond Vendor's Share – No Costs [Para 19].
 

Criminal Law - Sections 353 and 504 IPC - Quashing of FIR – Section 482 CrPC – Allegations Vague and Non-Specific – FIR and Charge Sheet Quashed - FIR was registered against the petitioner for allegedly abusing and attempting to assault police officials while being apprehended in connection with another case – Complaint contained vague and generalized accusations without specifying the abusive words used or the nature of the assault – No injuries alleged and no forceful resistance proved – Held: Mere abusive language does not fulfill the ingredients of Sections 353 and 504 IPC – Entire proceedings quashed to prevent abuse of process and secure ends of justice [Paras 2-7].

Decision: Petition allowed – Entire proceedings in C.C. No.1199/2021 arising from Cr. No.103/2020 of Channapatna East Police Station quashed – Pending interlocutory applications also disposed of.

Criminal Procedure – Alteration of Charges – Power Under Section 216 CrPC Exclusive to Court – Petition by Prosecution Impermissible - Court reaffirmed that only the trial court, not any party, can invoke Section 216 CrPC to alter or add charges – Held: Filing of such petitions by prosecution or accused is contrary to the scheme of the Code and delays justice [Paras 16-20].

Misuse of Section 216 CrPC – Prosecution-Led Petition Leading to Charge Alteration Set Aside – Jurisprudence Violated - Investigating officer had proposed specific charges which were directly accepted by the Sessions Judge – Held: Such action is procedurally unsound and violates criminal jurisprudence – Sessions Court erred in abdicating its judicial discretion [Paras 17, 21].

Delay and Prejudice – Reframing Charges After 56 Witnesses – Court Criticized Attempt to Derail Trial - Petition seeking alteration came after extensive trial progress including key witness testimonies – Court held that late-stage charge changes undermine accused’s fair trial rights and prolong litigation unnecessarily [Paras 5, 21].

Final Decision – Order of Sessions Judge Set Aside – Trial to Continue Without Amended Charges - High Court quashed the impugned order passed in Crl.MP.No.308 of 2025 in SC.No.110 of 2016 – Directed trial to proceed without altered charges [Para 22].