'Attempt To Transform Civil Dispute Into Criminal Matter', Supreme Court Quashes Workplace Harassment Case

Update: 2025-01-24 15:44 GMT
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The Supreme Court on January 24 quashed a workplace harassment case filed by a female employee against her colleagues, observing that the allegations arose from employment disputes that had been exaggerated into a criminal matter.The Court noted that the proceedings against the appellants were a deliberate “attempt to reclassify the nature of the proceedings from non-cognizable to cognizable...

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The Supreme Court on January 24 quashed a workplace harassment case filed by a female employee against her colleagues, observing that the allegations arose from employment disputes that had been exaggerated into a criminal matter.

The Court noted that the proceedings against the appellants were a deliberate “attempt to reclassify the nature of the proceedings from non-cognizable to cognizable or to transform a civil dispute into a criminal matter, potentially aimed at pressurizing the appellants into settling the dispute with the complainant.”

The bench of Justices Dipankar Datta and Prashant Kumar Mishra was hearing the case where the complainant alleged that the appellants had forcibly demanded her resignation under the threat of dismissal, confiscated her belongings, and physically and verbally harassed her. She also claimed that her intellectual property stored on the company's laptop was unlawfully seized.

The complaint was filed against the appellants for offenses under Sections 323 (voluntarily causing hurt), 504 (intentional insult to provoke breach of peace), 506 (criminal intimidation), 509 (insulting modesty of a woman), and 511 (attempt to commit an offense) of the Indian Penal Code.

Aggrieved by the High Court's refusal to quash the criminal proceedings, the Employees of the Company appealed to the Supreme Court.

Setting aside the High Court's decision, the judgment authored by Justice Datta observed that the Appellants were wrongly arrayed as accused as the ingredients of the aforementioned offences were not satisfied in the complaint.

“After a thorough examination of the matter, including a review of the materials on record: viz., the complaint, the FIR, and chargesheet, we are of the view that none of the ingredients of Sections 323, 504, 506, and 509 of the IPC are present, even if they are taken at face value and accepted in their entirety. The complaint is bereft of even the basic facts, which are absolutely necessary for making out an offence.”, the court said.

The Court noted that “the criminal proceedings were initiated by the complainant against the appellants with mala fide intentions, specifically to wreak vengeance, cause harm, or coerce a settlement.”

Accordingly, the Court allowed the appeal and quashed the pending criminal case against the Appellants.

Case Title: MADHUSHREE DATTA VERSUS THE STATE OF KARNATAKA & ANR.

Citation : 2025 LiveLaw (SC) 108

Click here to read/download the judgment

Appearance:

For Petitioner(s) Mr. Sidharth Luthra, Sr. Adv. Mr. Srijoy Das, Adv. Ms. Prerna Mehta, AOR Mr. Anmol Kheta, Adv. Mr. Ritik Gupta, Adv.

For Respondent(s) Mr. D. L. Chidananda, AOR Dr. J. P. Dhanda, AOR Ms. Raj Rani Dhanda, Adv. Dr. Ashok Vasishtha, Adv.

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