Mini Trial at Pre-Trial Stage Impermissible – High Court Cannot Weigh Medical Evidence to Quash 498A FIR: Supreme Court Restores  Case Against Husband

“Consistency in Judicial Orders Is Hallmark of Justice – Quashing by Coordinate Bench Without Referring Earlier Order Is Judicial Impropriety”- Supreme Court sharply criticized the Karnataka High Court for prematurely quashing criminal proceedings under Sections 498A, 324, 355, 504, and 506 IPC against the respondent-husband on the ground that medical evidence allegedly did not match the FIR.

Calling the High Court’s reasoning “judicial caprice” and its order “vitiated by arbitrariness,” the Bench of Justices P.S. Narasimha and Joymalya Bagchi ruled:

“The judge erred in law by embarking upon an enquiry with regard to the credibility or otherwise of the allegations in the FIR/Chargesheet… In doing so, the Judge had undertaken a mini trial to quash the proceeding which is impermissible in law.”

The Court allowed the wife’s appeal and restored the criminal proceedings against the husband, holding that the High Court’s quashing order was not only premature but also violated the principle of judicial consistency, as a coordinate bench had earlier refused to quash the case against other in-laws.

Wife Alleges Dowry Harassment, Physical Assault — Police Recover Evidence and Record Witness Statements

The case arose from a complaint filed by the appellant, Renuka, against her husband and in-laws, alleging harassment, dowry demands of ₹2 lakhs, and physical assault.

According to the FIR, the marriage took place in 2012 and the couple had two children. The husband allegedly developed an illicit relationship and, on October 27, 2020, he along with others came to the wife’s parental house, threw chilli powder in her eyes, and assaulted her and her relatives with slippers and stones.

The police filed a charge sheet, recovered material evidence (slippers and stones), and recorded statements including that of neighbour Suvarna Andri, who witnessed the assault.

High Court Quashed Proceedings Against Husband Despite Medical Report Showing Injury

Earlier, a Single Judge of the High Court had refused to quash proceedings against the in-laws, holding the wound certificate demonstrated that the wife suffered simple injuries.

However, a coordinate bench later quashed the proceedings against the husband, holding that the wound certificate did not support the allegation of assault with a blunt weapon.

Criticizing this finding, the Supreme Court observed:

“The judge erred in comparing the nature of assault described in the FIR vis-à-vis wound certificate and coming to a finding that the allegations are untrue… It was unwarranted to weigh ocular version vis-à-vis medical evidence at the pre-trial stage.”

“No Contradiction Between FIR and Medical Report – Trial Court Must Examine the Evidence”

Relying on the landmark ruling in R.P. Kapur v. State of Punjab and a long line of cases including Neeharika Infrastructure v. State of Maharashtra, the Court reiterated that: “The High Court would not embark upon an enquiry as to whether the evidence in question is reliable or not. That is the function of the trial Magistrate.”

It further noted that the wound certificate corroborated the FIR, and an independent eyewitness supported the prosecution version: “It cannot be said the case falls in the category of those cases where there is no legal evidence or evidence is manifestly and clearly inconsistent with the accusation.”

“Judicial Inconsistency Undermines Justice – Earlier Order Against In-Laws Not Even Considered”

A striking aspect of the judgment is its rebuke to the High Court for violating judicial discipline by ignoring an earlier decision by a coordinate bench that refused to quash the case against the in-laws.

“It was incumbent on the Judge while quashing the proceeding against the respondent-husband to refer to the earlier decision of the coordinate bench… Failure to do so infraction judicial propriety and discipline.”

The Court warned against forum shopping and inconsistent outcomes: “Inconsistent decisions coming out from different benches shake public trust and reduce litigation to a punter’s game… spoiling the clear stream of justice.”

High Court Order Quashing Charges Against Husband Set Aside

The Supreme Court allowed the appeal, restored the criminal proceedings against the husband, and directed that they continue in accordance with law:

“The order dated 16.02.2024 is set aside and the proceeding against the respondent-husband is revived.”

Date of Decision: April 29, 2025