Madras High Court | Plea for FIR Against Woman Rejected | Allegations of Blackmail Termed ‘Calculated Attempt’ to Defame and Misuse Criminal Law
Isabella Mariam
The Madras High Court at Madurai, Single Bench of Justice Shamim Ahmed dismissed a criminal revision petition filed under Sections 438 and 442 of the Bharatiya Nagarik Suraksha Sanhita, 2023, challenging a Magistrate’s refusal to order registration of an FIR. The case involved allegations that the respondent fraudulently obtained ₹45 lakhs through coercion. The Court found the petition baseless, observing that such claims appeared designed to tarnish the respondent’s reputation. Emphasising that criminal law cannot be invoked as a tool for defamation, the Bench underlined the need to safeguard women’s dignity while upholding the country’s cultural and traditional values.
The petitioner, R. Sathish, sought to set aside the order dated 03.04.2025 of the Judicial Magistrate Court No. II, Kovilpatti, in Crl.M.P. No. 535 of 2025. The revision petition challenged the Magistrate’s refusal to direct registration of a First Information Report (FIR) against the second respondent, Rengapriya.
According to the petitioner, he had known the second respondent since 2015. He alleged that beginning in 2019, she had fraudulently obtained a sum of ₹45,00,000 by threatening to accuse him of cheating her through a false promise of love and intimacy. He contended that this amounted to blackmail and unlawful coercion. Aggrieved by her actions, the petitioner lodged a complaint on 01.03.2025 before the Kovilpatti All Women Police Station, which was registered as CSR No. 358 of 2025. Despite the complaint, no FIR was registered.
When no action was forthcoming, the petitioner escalated the matter by submitting representations on 13.03.2025 to the Deputy Superintendent of Police, Kovilpatti, and the Superintendent of Police, Thoothukudi District. Again, no action followed. Consequently, he approached the Judicial Magistrate Court No. II, Kovilpatti, by filing Crl.M.P. No. 535 of 2025, seeking a direction to the police to register an FIR and investigate the alleged fraud. The Magistrate, after hearing, dismissed the petition on 03.04.2025 on the ground that no specific allegations were made and that the complaint lacked merit.
In the revision before the High Court, counsel for the petitioner argued that the Trial Court had failed to appreciate the financial distress suffered by the petitioner. It was urged that the petition contained prima facie allegations sufficient to warrant registration of an FIR, and that the Magistrate’s order was erroneous. The petitioner claimed that the second respondent had exploited his trust and friendship, resulting in unlawful gain, and insisted that justice demanded police action.
The State opposed the revision petition. The Government Advocate for the police argued that the Magistrate had carefully considered the facts and rightly found no basis for ordering registration of an FIR. It was contended that the complaint was motivated and appeared to be an attempt to malign the reputation of a woman. The State urged the Court not only to dismiss the revision but to impose exemplary costs so that such petitions would not be used to defame individuals under the guise of criminal process.
The Court noted: “Entertaining petitions of this nature would likely cause irreparable harm to the reputation of the woman. The averments made in the petition appear to be a calculated attempt to defame the woman.”
The Court expressed dissatisfaction with the petitioner’s contentions, stating: “This Court is not convinced by the contentions raised by the learned counsel for the Petitioner. The petition lacks merit and seems to be filed with ulterior motives.” It further held: “Thus, this Court is inclined to dismiss the petition to prevent misuse of the legal process and protect the dignity and reputation of those unfairly targeted.”
The judgment went on to stress the importance of cultural and societal values, observing: “The societal context and cultural norms prevalent in our country must be given due consideration. Unlike some Western countries where certain types of relationships may be more prevalent and socially accepted, our nation places significant importance on its rich cultural heritage and traditional values, which are integral to its identity.”
The Court noted the potential impact of such allegations on the personal life of the second respondent: “In the present case, this Court finds that the Petitioner's allegations appear to be an attempt to harm the reputation of the 2nd Respondent/Rengapriya, which could potentially make it difficult for her family to arrange her marriage with a suitable family of their choice in the future.”
It cautioned that allowing such claims without proper evidence would be damaging, recording: “Allowing such actions without proper basis could harm our cultural and traditional values. Therefore, the Court must be cautious and not entertain frivolous petitions aimed at defaming individuals.”
Finally, the Court directed: “This Court does not find any merit in the Petitioner's case and the learned Trial Court had rightly dismissed the case of the Petitioner by way of the reasoned and speaking order, dated 03.04.2025.”
"Accordingly, with the above observations, this Criminal Revision Petition is dismissed and the file is consigned to record. There shall be no order as to costs."
Advocates Representing the Parties
For the Petitioner: Mr. V. Vishnu, Advocate
For the Respondents: Mr. M. Karunanithi, Government Advocate
Case Title: R. Sathish vs. The Inspector of Police, Kovilpatti West Police Station & Anr.
Neutral Citation: 2025: MHC:2225
Case Number: Crl.R.C.(MD)No.1266 of 2025
Bench: Justice Shamim Ahmed
