The Punjab and Haryana High Court has modified an order framing charges against a Gurugram-based doctor and others in an assault case, holding that the material available on record did not prima facie justify a charge of grievous hurt under Section 325 of the Indian Penal Code (IPC). The Court, however, allowed the prosecution to proceed on other charges, including voluntarily causing hurt and wrongful confinement.
The ruling was delivered by Justice Sumeet Goel on May 29, 2026, while deciding two connected criminal revision petitions arising from the same order passed by an Additional Sessions Judge, Gurugram.
Background of the Case
The dispute stemmed from FIR No. 173 dated August 27, 2023, registered at New Colony Police Station, Gurugram, on the complaint of Nishant Verma. The FIR initially invoked several offences, including allegations of assault, wrongful restraint and robbery. During investigation, police later removed the robbery-related allegation and filed a charge-sheet against the accused under Sections 323, 325, 331, 341, 201, 506 and 34 IPC.
The complainant alleged that he sustained multiple injuries, including dental injuries. Medical opinions obtained from government doctors repeatedly described most injuries as simple in nature. Dental opinions also noted the absence of radiological evidence supporting a more serious injury.
The trial court nevertheless directed framing of charges under Section 325 IPC (grievous hurt) and Section 331 IPC, prompting challenges from both sides.
Justice Goel examined the medical material and referred to judicial precedents dealing with proof of fractures and grievous hurt. The Court noted that courts must exercise caution before treating an injury as grievous in the absence of reliable radiological evidence.
The Court observed that the available medical opinions consistently indicated that the injuries were simple in nature and that there was no adequate material demonstrating a fracture or other injury attracting the ingredients of grievous hurt.
Referring to the legal requirement for framing charges, the Court emphasized that the material on record must disclose the essential ingredients of the alleged offence before a charge can be sustained.
The Court also declined to examine, at this stage, the complainant's challenge regarding persons who had been exonerated during investigation, observing that such issues fell outside the limited scope of the revision petitions.
Allowing the revisions in part, the High Court modified the trial court's order dated November 20, 2024. It held that the accused should face trial under Sections 323, 330, 341, 201, 506 and 34 IPC, while the charge under Section 325 IPC was not sustained.
The Court clarified that its observations were confined to the stage of charge and should not be treated as an opinion on the merits of the trial.
Case Details:
Case Title: Dr. Rohit Lalit and Others v. State of Haryana and Another connected with Nishant Verma v. State of Haryana and Others
Case Numbers: CRR-2289-2025 (O&M) and CRR-1437-2025 (O&M)
Judge: Justice Sumeet Goel
Decision Date: May 29, 2026
