Facts:

This case pertains to two cross FIRs. The dispute involves a landlord-tenant relationship that escalated into serious criminal allegations. The sections under the Indian Penal Code (IPC) invoked in these FIRs are Section 323 (voluntarily causing hurt), Section 354 (Assault or use of criminal force on a woman with the intent to outrage her modesty), Section 354B (Assault or use of criminal force to disrobe a woman), Section 451 IPC (House-trespass in order to commit an offence), Section 506 (criminal intimidation), Section 509 (Word, gesture, or act intended to insult the modesty of a woman).

FIR was filed by a woman (Respondent No.2) against her landlord (Petitioner), accusing him of outraging her modesty. She alleged that the landlord used criminal force with the intent to insult and intimidate her.

Another FIR was filed by the landlord against his tenant (Respondent No.2) claiming that the tenant had likewise outraged his modesty and committed house-trespass with criminal intent.

Both FIRs were cross-complaints from the parties. The dispute, originally a landlord-tenant issue, escalated into serious accusations of assault and modesty outraging. However, the parties eventually reached a settlement and approached the court for quashing the FIRs.

Petitioners’ Contention:

The petitioners (both landlords and tenants, in their respective cases) sought quashing of the FIRs based on facts that the dispute between the parties had been amicably resolved through mutual settlement, the criminal charges were no longer relevant, as the complainants did not wish to pursue the case further. The continued criminal proceedings would unnecessarily prolong the legal hardship, despite the settlement.

Court’s Observations:

The Delhi High Court expressed serious concern over the misuse of legal provisions, especially Sections 354, 354A, 354B, 354C, and 354D IPC, which deal with crimes involving the modesty of women. The Court noted that such provisions are often used inappropriately for ulterior motives, especially in civil disputes like landlord-tenant cases.

The Court highlighted the growing trend of filing frivolous and baseless cases under these sections. It noted that such allegations could tarnish the reputation of the accused and divert valuable police and judicial resources.

The Court observed that in this particular case, the core issue was a landlord-tenant dispute, but it was escalated through false allegations involving serious offences, including outraging modesty. Even children were drawn into the allegations, which the Court deemed as an abuse of legal processes.

The Court took judicial notice of the fact that frivolous cases consume significant police time and energy, hampering the investigation of serious cases, ultimately leading to poor-quality investigations in more grave matters.

The Court further remarked that serious allegations under Sections 354 and 354A should not be made lightly, as they can have long-term consequences on the accused’s social standing and life.

Court’s Decision:

Given the settlement reached between the parties, the Court exercised its powers under Section 482 Cr.P.C. to quash the FIRs. It referenced the Supreme Court ruling in Gian Singh v. State of Punjab (2012) 10 SCC 303, which allows quashing of criminal cases where the dispute is civil in nature and the chances of conviction are remote due to the settlement.

However, the Court expressed its disapproval of the parties abusing the process of law by filing false cases under serious sections of the IPC. It held that parties should not be allowed to escape without consequences for filing such frivolous and baseless complaints.

To deter the parties from repeating such misuse of the legal process, the Court imposed costs on both petitioners for filing false cases:

– Deeksha Rai