Pranav B Prem

The Supreme Court on January 24 quashed a workplace harassment case filed by a female employee against her colleagues, observing that the allegations primarily stemmed from employment disputes and had been exaggerated into a criminal matter. The bench of Justices Dipankar Datta and Prashant Kumar Mishra emphasized that the case reflected an "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."

Background of the Case

The complainant, employed as a Technical Systems Analyst with Juniper Networks India Private Limited, alleged that she had been subjected to harassment by the management. According to her complaint, on October 25, 2013, the Human Resources Manager, Madhushree Datta, demanded her resignation under duress, threatening immediate dismissal if she refused. The complaint further alleged that her belongings, including a laptop containing her intellectual property, were confiscated, and she was forcibly escorted out of the office by security personnel, who allegedly engaged in physical and verbal harassment. A Non-Cognizable Report (NCR) was initially registered on October 26, 2013, but two months later, an FIR was filed under Sections 323 (voluntarily causing hurt), 504 (intentional insult), 506 (criminal intimidation), 509 (insulting modesty of a woman), and 511 (attempt to commit an offense) of the Indian Penal Code. A chargesheet was subsequently filed, naming the HR Manager and another senior official as accused.

Supreme Court's Observations

The Court conducted a detailed review of the materials on record, including the complaint, the FIR, and the chargesheet, and concluded that none of the ingredients required to constitute the alleged offenses were present, even if the allegations were taken at face value. Justice Datta, authoring the judgment, stated: "The complaint is bereft of even the basic facts, which are absolutely necessary for making out an offense under Sections 323, 504, 506, and 509 of the IPC. The allegations appear to be a deliberate attempt to exert pressure and coerce a settlement."

The Court further noted the inconsistencies between the initial NCR and the subsequent FIR, particularly the inclusion of accusations that were not part of the original complaint. It observed that the complainant had also approached the Labour Court regarding her termination, highlighting the primarily civil nature of the dispute.

Key Findings:

1. No Prima Facie Case: The Court held that the chargesheet failed to establish the essential elements of the alleged offenses. For instance, there was no evidence of physical harm or criminal intent as required under Section 323. Similarly, the alleged use of "filthy language" did not meet the threshold to invoke Sections 504 or 509.

2. Mala Fide Intent: The Court emphasized that the criminal proceedings were initiated with mala fide intentions, likely aimed at causing harm or pressuring the accused into a settlement.

3. Civil Dispute in Criminal Garb: The Court observed that the allegations primarily revolved around employment issues and lacked any substantial basis for criminal charges.

Quashing the Proceedings

Setting aside the Karnataka High Court's refusal to quash the criminal proceedings, the Supreme Court quashed the chargesheet and all related proceedings against the accused. It clarified that the findings in the judgment were limited to the criminal case and would not affect the complainant's ongoing proceedings before the Labour Court.

Cause Title: Madhushree Datta Vs The State Of Karnataka & Anr.

Case No: Criminal Appeal NO. 4884 OF 2024

Date: January-24-2025

Bench: Justice Dipankar Datta, Justice Prashant Kumar Mishra

[Read/Download order]