Allegations In The FIR And Chargesheet Did Not Disclose The Necessary Ingredients For Offences Under Sections 269, 270, And 504, IPC (Paras 16, 19)
Workplace Disputes Should Not Be Criminalized – Mere Verbal Admonition By A Superior Did Not Amount To Intentional Insult (Para 28)
Section 269, IPC – No Evidence That PPE Kit Shortage Led To Spread Of Infection – No Negligence Established (Para 17)
Section 270, IPC – No Malignant Intention Or Mens Rea Proved (Para 17)
Section 504, IPC – Requires Intentional Insult With Provocation – No Evidence Of Mens Rea – Workplace Discipline Not Covered (Para 25)
Allowing Such Cases Would Set A Dangerous Precedent – Workplace Disciplinary Measures Should Not Be Interpreted As Criminal Offences (Paras 27, 28)
High Court Erred In Dismissing The Quashing Petition – Supreme Court Intervened To Prevent Misuse Of Criminal Law (Paras 29, 30)

Supreme Court Allowed The Appeal – Set Aside High Court Judgment – Quashed Criminal Proceedings Against The Appellant (Paras 30, 31)

Acts And Sections Discussed:

1. Constitution Of India, 1950 – Article 226 – Power Of High Court To Quash Criminal Proceedings – Extraordinary Jurisdiction – Abuse Of Process – Ends Of Justice (Para 14)

2. Code Of Criminal Procedure, 1973 – Section 482 – Inherent Powers Of High Court – Quashing Of FIR And Chargesheet – No Prima Facie Case – Principles From Precedents (Paras 14, 22)

3. Indian Penal Code, 1860 – Section 269 – Negligent Act Likely To Spread Infection Of Disease – Mens Rea Required – No Material Evidence (Paras 16, 17)
-- Section 270 – Malignant Act Likely To Spread Infection Of Disease – No Evidence Of Willful Negligence (Para 17)
-- Section 504 – Intentional Insult With Intent To Provoke Breach Of Peace – No Intention Or Mens Rea – Workplace Admonition Not Covered (Paras 19, 23, 25)

Subjects:

Quashing Of FIR – Abuse Of Process – No Prima Facie Case – Workplace Discipline – Intentional Insult – Mens Rea – No Provocation – Covid-19 Pandemic – Director’s Authority – Supreme Court Intervention

Facts:

1. Nature Of The Litigation

-- Criminal Appeal Against High Court Judgment – Petition Under Section 482, Code Of Criminal Procedure, 1973 – Dismissal Of Quashing Petition – Alleged Workplace Harassment (Paras 3, 6)

2. Who Approached The Court And For What Remedy?

-- Appellant – B.V. Ram Kumar – Director Of Institute(Workplace) – Filed Criminal Petition Before High Court Seeking Quashing Of Chargesheet – High Court Dismissed The Petition – Appellant Filed Special Leave Petition Before Supreme Court (Paras 3, 5)

3. Reason For Filing The Case

-- Complaint Filed By Assistant Professor – Allegation That Appellant Reprimanded Her In A Loud Voice – Alleged Mental Harassment – Non-Provision Of PPE Kits During Covid-19 Pandemic (Paras 4, 5)

4. What Had Already Been Decided Until Now?

-- High Court Held That Allegations Required Trial – Dismissed Quashing Petition – Held That The Case Was Not Fit For Quashing Under Section 482, Code Of Criminal Procedure, 1973 (Para 6)

Issues:

a. Whether The Allegations In The FIR And Chargesheet Disclosed A Prima Facie Case For Offences Under Sections 269, 270, And 504, Indian Penal Code, 1860? (Para 13)
b. Whether The High Court Erred In Dismissing The Quashing Petition Despite Absence Of Essential Ingredients Of The Offences? (Para 14)
c. Whether Workplace Reprimand And Alleged Lack Of PPE Kits Could Attract Criminal Liability? (Paras 16, 17)

Submissions/Arguments:

Appellant’s Submissions

a. Criminal Proceedings Were A Clear Abuse Of Process – Initiated With Mala Fide Intent – No Mens Rea Or Actus Reus (Paras 7, 8)
b. Even If Allegations Were Taken At Face Value, They Did Not Make Out Any Offence – No Prima Facie Case (Para 8)
c. Workplace Discipline And Administrative Authority Of The Director Misinterpreted As Intentional Insult (Para 26)
d. No Evidence Of PPE Shortage – Witnesses Stated That PPE Kits And Sanitizers Were Available (Para 17)

Respondent's Submissions

a. Allegations Disclosed Continuous Harassment – Prima Facie Case Made Out – High Court Order Justified (Paras 9, 10)
b. Appellant’s Conduct Was Inappropriate – Workplace Norms Violated – Intentional Insult Under Section 504, IPC (Paras 9, 10)
c. Complainant Suffered Distress Due To The Altercation – Evidence Of Intentional Insult (Para 9)

Ratio Decidendi:

a. Criminal Proceedings Must Be Quashed If FIR And Chargesheet Do Not Disclose A Prima Facie Offence (Para 14)
b. Intentional Insult Under Section 504, IPC, Requires Provocation To Breach Public Peace – Workplace Admonition Does Not Qualify (Paras 19, 23)
c. Mens Rea Is Essential For Offences Under Sections 269, 270, And 504, IPC – Mere Workplace Dispute Does Not Constitute Criminal Offence (Para 24)
d. Constitutional Courts Have The Power To Quash Proceedings To Prevent Abuse Of Process And Secure Ends Of Justice (Para 14)