The Allahabad High Court on Monday set aside criminal proceedings against a Bhadohi woman accused of trafficking and exploiting two minor domestic workers, saying the evidence on record did not show forced labour or coercion. Justice Sameer Jain delivered the order after hearing arguments from both sides over whether the charges should proceed to trial.
Background
The case began in September 2024 when police discovered a 15-year-old girl working as a maid in the home of Seema Beg and her husband, Zahid Jamal Beg. A few days earlier, another minor domestic worker in the same household had died under suspicious circumstances, reportedly by suicide. The FIR alleged that both girls were underpaid, scolded, and occasionally beaten, and that this amounted to exploitation, forced labour, and violation of child protection laws.
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The police later filed a charge sheet under provisions relating to human trafficking under the Bharatiya Nyaya Sanhita, offences under the Juvenile Justice Act, and violations of the Bonded Labour System (Abolition) Act. Seema Beg moved the High Court seeking to quash the proceedings.
Court’s Observations
During the hearing, the applicant’s counsel emphasized that the girls had been working with the consent of their families, and that there was no recruitment through force, fraud, or threats - key elements needed to establish trafficking. They argued that while payments may have been modest, the family of one victim had accepted it, and there was no indication of bondage or withholding of wages.
The State, however, maintained that employing minors in these conditions amounted to exploitation and violated constitutional safeguards against forced labour. “This is not just an employment arrangement. It reflects economic and social coercion,” the Additional Advocate General told the court.
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The bench closely examined the statements recorded during investigation. Justice Jain noted that although the girls were young and financially vulnerable, the record did not show that they were recruited for exploitation. “The material does not indicate use of threat, force, deception, or inducement in obtaining their consent,” the bench observed. It also pointed out that there was no allegation of the employer withholding earnings or keeping the children in bondage, which are necessary to invoke the Juvenile Justice and bonded labour provisions.
Decision
Finding that no offence under Section 143 of the BNS (trafficking), Section 79 of the Juvenile Justice Act, or Section 4/16 of the Bonded Labour Act623 was made out, the High Court quashed the charge sheet and the ongoing criminal trial.
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“In absence of prima facie evidence of exploitation or coercion, continuation of proceedings would be an abuse of process of law,” the court concluded.
The application was allowed, and the entire criminal case against Seema Beg was set aside.
Case Title: Seema Beg vs. State of Uttar Pradesh & Another
Court: High Court of Judicature at Allahabad
Case Number: Application U/S 528 BNSS No. 35862 of 2025
Bench: Justice Sameer Jain
Trial Court Case: Sessions Trial No. 496 of 2025, arising out of Case Crime No. 185 of 2024, P.S. Bhadohi, Gyanpur
Date of Judgment: 07 October 2025