The Supreme Court recently dismissed a cheating case (under Section 415 of the IPC) filed against the parents of a man who married another woman instead of the complainant.
The Court noted that the complainant was a 29-year-old, well-educated, and independent woman, making it difficult to believe that the parents' actions had significantly influenced her decision-making.
Additionally, the Court criticized the High Court’s remarks against the appellants’ son, stating that adverse comments should not be made against a person who was not a party to the proceedings or given a fair opportunity to present his side. The Court ordered the removal of such remarks from the records.
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Background of the Case
The complainant alleged that she was in a relationship with the appellants' son and had entered into a physical relationship with him based on his promise of marriage. On one occasion, he introduced her to his parents, who reportedly accepted her as their future daughter-in-law. However, later, the son informed her that his parents had arranged his marriage with another woman.
The complainant argued that the parents played a crucial role in this matter. Their acceptance of her relationship with their son gave her confidence, but she was ultimately abandoned when he married someone else.
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Arguments by the Appellants (Parents):
The appellants (parents) contended that the complaint did not contain any allegations stating that they had deceived or misled the complainant into believing that their son would marry her.
There was also no claim that they had forced their son to marry someone else or that they had knowledge of his relationship with the complainant.
Arguments by the Complainant and the State:
The complainant insisted that the parents’ role was vital since their apparent approval of the relationship had influenced her decisions. She argued that she was deceived and left without support when their son married another woman.
The state’s senior counsel fairly conceded that, based on the available facts, the appellants could not be held liable under Sections 417 (cheating) and 109 (abetment) of the IPC.
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The Supreme Court examined the legal provisions under Section 415 of the IPC, which defines "cheating" as deceiving a person fraudulently or dishonestly to induce them to act in a way that causes harm.
"We do not find any act or conduct on the part of the appellants that can be termed illegal, let alone criminal in nature. No ingredients of any offense under IPC appear to be made out. As such, no case under Section 415 of IPC is established against the appellants."
The Court emphasized that the complainant was a 29-year-old, well-educated woman, running her own business. Given her maturity and experience, it was difficult to conclude that she was easily misled by the appellants' alleged statements.
"Considering the complainant’s age and educational background, we are not inclined to believe that the appellants' statements, if any, led her to develop an intimate relationship with their son."
The Court further noted that the main allegations were against the son, and quashing the case against the parents would not impact the proceedings against him.
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The Madras High Court, while dismissing the quashing petition, had commented that allowing the petition would enable the appellants' son to "spoil women of marriageable age in a similar manner."
The Supreme Court strongly disapproved of this remark, stating that it was unjustified since the appellants' son was not a party to the proceedings and had no opportunity to present his defense.
"The High Court should have refrained from making adverse comments against a third party who was not before it and was not given a fair chance to be heard."
Following this, the Supreme Court directed the removal of these remarks from the High Court’s judgment record.
The Supreme Court ruled that:
The criminal case against the parents should be dismissed as no legal offense was found against them.
The High Court’s remarks against their son should be deleted from the records.
The case against the son could proceed independently if legally required.
This judgment reaffirmed that courts must ensure fairness and not allow cases that could lead to judicial overreach or an abuse of legal processes.
