Video Conferencing Is Not a License to Dilute Courtroom Decorum: Bombay High Court Dismisses Police Officer’s Plea Against Show-Cause Over Virtual Misconduct

“Comfort of Office Does Not Mean Casual Conduct”—Bombay HC Refuses to Quash Trial Judge’s SOP Recommendation Against Police Inspector’s Insolence During Video Testimony. High Court dismissed a police officer’s plea to quash a letter issued by the Sessions Judge, Beed, to the Director General of Police recommending the framing of a Standard Operating Procedure (SOP) for video conferencing by investigating officers. The recommendation came after the officer, a Senior Police Inspector, allegedly exhibited insolent and inappropriate behaviour while deposing via mobile phone in a criminal trial.

Rejecting the officer’s defence and prayer for relief, the Division Bench of Justices Revati Mohite Dere and Dr. Neela Gokhale observed: “The comfort and convenience of his office definitely did not allow him to take the Court proceedings casually… the conduct of the Petitioner was sure to cause obstruction in the administration of justice.”

The petitioner, Bramhanand Raosaheb Naikwadi, was serving as Senior Police Inspector, Nerul Police Station, Navi Mumbai, and had appeared through video conferencing via mobile phone before the Beed Sessions Court on January 20, 2025, to give evidence in a 2014 Sessions case, in which he was the investigating officer.

The Trial Judge, displeased with the manner in which the petitioner conducted himself during the proceedings, issued a letter on January 22, 2025, to the DGP, Maharashtra, recommending the formulation of SOPs for virtual evidence to maintain courtroom decorum. The petitioner challenged this letter, calling it punitive and excessive.

He submitted that he had been on duty for a Coldplay concert held between January 18–21, 2025, a high-security international event, and was under significant stress. He explained that while giving evidence from his chamber, a constable entered without knocking and he instinctively gestured to stop him, leading to a misunderstanding. He also cited poor internet connectivity and claimed there was no deliberate impropriety on his part.

Evidence by IO Demands Respect and Discipline

The Court disagreed with the petitioner’s explanations and held that his conduct during the video testimony fell far short of expected standards, especially considering his role as the investigating officer.

The Bench noted several instances of inappropriate conduct:

• He kept muting his microphone and was seen talking to someone else in the room.

• He laughed when admonished by the Judge not to converse during deposition.

• He told the Additional Public Prosecutor that “everything is written in the panchanama” rather than answering questions directly.

• He answered a phone call, allegedly from the Commissioner of Police, during the testimony.

The Court remarked: “Recording of evidence is a crucial part of a trial. The manner in which the Petitioner conducted himself is sure to cause obstruction in the administration of justice.”

SOP Suggestion Not an Adverse Administrative Action

Addressing the key grievance—that the Trial Judge’s letter was disproportionate—the Court clarified: “The Trial Judge’s letter merely suggested the framing of SOPs to the Petitioner’s superior officer. It does not reflect any personal vendetta, nor does it constitute punitive action.”

It emphasized that video conferencing is not a relaxation of standards, and that: “Being permitted to depose from the comfort of office does not permit casual, insolent behaviour. The suggestion for SOP was warranted in light of the events.”

Dismissing the petition, the Bombay High Court held that the letter issued by the Trial Judge did not suffer from any illegality or malice. The officer is free to respond to any show-cause notice issued by his departmental superiors on its own merits, but no judicial interference was warranted in the Trial Judge’s administrative recommendation.

Justice Revati Mohite Dere concluded: “We do not find any infirmity or illegality on the part of the Trial Judge in issuing the impugned letter… putting the Petitioner on trial for such conduct may well be justified, and framing SOPs will help prevent future misconduct.”

Date of Decision: April 16, 2025