Supreme Court Dismisses Challenge To High Court Orders, Holds Courtroom Remarks Cannot Be Treated As Humiliation

A bench of Justices Sudhanshu Dhulia and Ahsanuddin Amanullah heard Special Leave Petition (Criminal) No. 15500 of 2024, in which the petitioners challenged the Rajasthan High Court's disposal of a habeas corpus petition as infructuous and the subsequent refusal to seek an explanation from police officers for remarks made in court about the marital status of one of the petitioners.

The Court dismissed the petition and upheld the High Court's handling of the matter, finding that the habeas corpus petition became infructuous when the alleged detenue returned home and that no direction had been issued by the High Court obliging police to file a written clarification. The Court emphasised that not every uncomfortable or embarrassing statement made during judicial proceedings amounted to humiliation actionable before the Court. The Court, in its reasoning, observed: "During court proceedings, many statements are made and questions are posed which may make a person uncomfortable, but all such statements or questions cannot be misconstrued as humiliating a person. After all, it is the duty of the Court to reach the truth of the matter and such exercise may demand putting forward certain questions and suggestions which may be uncomfortable to some." The bench also reproduced and relied upon the High Court's order dated 30.05.2024 to show that no written-direction to the police was issued, noting the order: "Learned GA cum AAG has produced the status report. We have perused the status report. Learned GA cum AAG seeks four weeks’ time to produce the corpus. Time prayed for is allowed. List the matter on 04.07.2024" The Supreme Court found the subsequent review petition and miscellaneous application to be misconceived and dismissed the present petition, disposing of pending applications.

Background

The petitioners had approached the Rajasthan High Court by way of a habeas corpus petition alleging that their mother was being unlawfully detained by private respondents and that police had failed to trace her despite missing person reports. During the High Court proceedings, police officials allegedly stated that Petitioner No.1's marriage had been dissolved by a decree of divorce and that her husband had remarried. Petitioner No.1 contended that those statements defamed and humiliated her and sought a direction that police furnish a written explanation of the basis for their assertions. The High Court, however, issued an order on 30.05.2024 that merely recorded production of a status report and granted time to the government advocate to produce the corpus, listing the matter for 04.07.2024. While the petitioners said the High Court accepted a request to procure clarification from the police, the record did not support that claim.

Before the next date, the alleged detenue returned home and the High Court dismissed the habeas corpus petition on 04.07.2024 as having become infructuous. A review petition against that order was dismissed on 23.07.2024. In August 2024 the petitioners filed a miscellaneous application seeking reconsideration and a direction to police to explain the basis for their court statements; the High Court dismissed that application as well. The petitioners then moved the Supreme Court, appearing in person, reiterating their grievance of public humiliation and defamation arising from police remarks made during court hearings.

The Supreme Court examined the record, held that the High Court's 30.05.2024 order did not direct the police to file any written clarification, and concluded that the reliefs sought became academic once the alleged detenue returned. The bench reasoned that courtroom questioning or statements made in pursuit of truth could, at times, cause discomfort but could not be equated with humiliation warranting judicial interference. The petitioners’ subsequent review and miscellaneous applications were held to be without merit, and the SLP was dismissed; pending applications were disposed of.

Case Details: Case No.: Special Leave Petition (Criminal) No. 15500 of 2024 (Citation: 2025 INSC 196) Case Title: Smt. Dhanlaxmi urf Sunita Mathuria & Anr. v. State of Rajasthan & Ors. Appearances: For the Petitioner(s): Petitioners appeared in person (names as in cause title) For the Respondent(s): Learned Government Advocate cum Additional Advocate General (as recorded in the High Court proceedings); State counsel for Respondents (no private counsel names recorded in the order)