Isabella Mariam

The High Court of Madras, Single Bench of Justice N. Sathish Kumar quashed the criminal proceedings initiated in 2024 against a group of men accused of unlawful assembly for installing an LED screen near a temple to show the live telecast of the Ayodhya Ram Mandir ceremony. The Court observed that gatherings during religious events may draw objections from certain groups, but such congregations by themselves do not amount to an unlawful assembly or public nuisance under the Indian Penal Code. Holding that the allegations lacked evidentiary basis, the Court concluded that continuing the prosecution would be an abuse of legal process.

The case arose from a complaint lodged by an individual alleging that a group of men had installed an LED screen in front of a temple at Kamarajapuram, Coimbatore, to display the live telecast of the Ayodhya Ram Mandir ceremony. It was claimed that this installation caused a traffic obstruction and disturbance to the general public. Based on the complaint, the police registered a case under Sections 143, 341, and 290 of the Indian Penal Code, relating to unlawful assembly, wrongful restraint, and public nuisance, respectively. Following investigation, a charge sheet was filed before the Judicial Magistrate at Coimbatore.

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The accused individuals approached the High Court seeking to quash the proceedings. They contended that the allegations were false and that no material evidence existed to substantiate the charges. They further stated that the LED screen had been placed within the temple premises and not on a public road, and therefore did not cause any obstruction or inconvenience. The petitioners also referred to a prior order of the High Court, which had permitted such events subject to certain conditions, asserting that they had complied with all those directions.

The State, maintained that the installation of the screen had led to congestion in a public area and amounted to a disturbance of public order. The case documents included the initial complaint, statements recorded during the investigation, and the charge sheet prepared by the investigating officer. The petition was filed invoking the provisions corresponding to Section 482 of the Code of Criminal Procedure (now Section 528 of the Bharatiya Nagarik Suraksha Sanhita), seeking the inherent powers of the Court to prevent misuse of judicial process. The evidence relied upon by the prosecution consisted primarily of the complaint and observations relating to the gathering at the site during the telecast

Justice N. Sathish Kumar examined the materials on record and referenced the earlier order in W.P.No.1430 of 2024, noting that the State had clarified that "functions / Bhajans / Annadhanams conducted in private enclosures like mandapams, private temples and any other private place does not require any permission from the police." The Court recorded that "it will be left open to the organizers to make arrangements for live streaming of the Pran Prathishta at Ayodhya," and that only events likely to spill over to public areas would require prior police intimation.

The Court further quoted the order’s state that "Bhakti towards God is only for peace and happiness and not to disturb the equilibrium prevailing in the society." Justice Kumar observed that it was common for people to gather during religious functions, but "merely because some people gathered to watch said functions, it cannot be said as an unlawful assembly so as to attract the offence." He stated that there was no evidence of public nuisance or disturbance of peace.

Citing the Supreme Court’s judgement in State of Haryana v. Bhajan Lal (1992 Supp (1) SCC 335), the Court reiterated that criminal proceedings can be quashed where "the allegations made in the First Information Report or the complaint, even if they are taken at their face value and accepted in their entirety, do not prima facie constitute any offence." The Court stated that in the absence of any act involving criminal force, mischief, or trespass, the offence of unlawful assembly under Section 143 IPC was not made out.

Justice Kumar recorded that directing the petitioners to undergo trial without evidence would be "a futile exercise and would infringe the right of the persons concerned." The prosecution materials, he noted, were insufficient to justify continuation of criminal proceedings.

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The Court stated: "Considering the above facts, this Court is of the view that the mere launching of an FIR by the prosecution itself is not sufficient to reach to the conclusion that the offences are made out." Justice Kumar found that "the materials collected by the prosecution do not support the case, therefore, continuing the prosecution on such shaky grounds or without any materials would amount to a clear abuse of the process of law."

"Accordingly, this Criminal Original Petition is allowed and the proceedings pending in C.C.No.1217 of 2024, on the file of the learned Judicial Magistrate No.I, Coimbatore District, is quashed as against the petitioners. Consequently, the connected miscellaneous petitions are closed."

Advocates Representing the Parties

For the Petitioners: Ms. B. Sruthi, for Ms. A. Jagadeeswari
For the Respondent: Mr. R. Vinothraja, Public Prosecutor (Coimbatore City)

Case Title: Sureshbabu and Others v. State Represented by the Inspector of Police, R.S. Puram Police Station, Coimbatore City
Case Number: Crl.O.P.No.27515 of 2025
Bench: Justice N. Sathish Kumar