Supreme Court quashes criminal proceedings against parents, holds trial would be abuse of process

A bench of Justices Ahsanuddin Amanullah and K. V. Viswanathan heard an appeal against a Madras High Court order which had refused to quash the chargesheet filed in P.R.C. No.16/2022 arising from Crime No.13/2022 (All Women Police Station, Theni). The appellants challenged the Single Judge's dismissal of their petition under Section 482 CrPC seeking to quash the criminal proceedings instituted against them for alleged cheating and abetment.

The Court allowed the appeal and set aside the impugned High Court judgment, holding that no prima facie case against the appellants was made out and that a trial against them would amount to an abuse of the process of the court. The bench noted that the State itself acknowledged on the facts and pleadings that the appellants could not be held criminally liable. The Court, in its reasoning, observed: "Having considered the matter, we find substance in the submissions of the learned counsel for the appellants. From the entire reading of the complaint itself, it is clear that the only reference by/reason of the complainant against the appellants was that they were the parents of the boy who was in a relationship with her, and on one occasion, she had also met the appellants with their son. In the complaint itself, it is stated that the son of the appellants did not want the appellants to stay there for some time, and immediately they were sent away. To our minds, this is also indicative of the fact that the appellants themselves were totally ignorant of what, if anything, was happening between their son and the complainant. Even otherwise, from what is alleged in the complaint itself, we do not find that there is any act or conduct on the part of the appellants which can be termed to be illegal per se, much less criminal in nature. No ingredients of any offence under the IPC appear to be forthcoming. As such, we are unable to hold that any offence under the ambit of Section 415 of the IPC is made out against the instant appellants." The Court further held that "trial against the appellants would be an abuse of the process of the Court and the same needs to be nipped in the bud," and accordingly quashed the proceedings against them while preserving the case against the son.

Background The dispute arose from a complaint by a woman who alleged that she had developed a relationship with the appellants’ son and entered into physical relations on assurances that he would marry her. She alleged that she had met the appellants with their son and that they had accepted her as a prospective daughter-in-law, but that the son later married another woman. The appellants petitioned the Madras High Court under Section 482 CrPC to quash the chargesheet insofar as it pertained to them, contending that the complaint contained no allegation that they had instigated, misrepresented, or forced the relationship, nor that they had knowledge of or involvement in the son’s conduct.

The High Court dismissed their petition. On appeal, the Supreme Court examined the complaint, statutory definitions (including Section 415 IPC on cheating), and relevant precedent. The bench relied on the principle that persons should be protected "against vexatious and unwarranted criminal prosecution" and that High Courts must intervene in deserving cases to prevent needless trials (as reflected in Vishnu Kumar Shukla v. State of U.P. and related decisions). The State, through senior counsel, conceded that the appellants could not be held liable on the pleadings. Applying these legal tests, the Court found that no ingredients of cheating or abetment were made out against the parents and that proceeding to trial would be unjustified. The appeal was allowed, the impugned judgment was set aside, the proceedings in P.R.C. No.16/2022 insofar as they related to the appellants were quashed, and the appellants were discharged from their bail bonds and sureties. The Court granted liberty to the State and complainant to continue proceedings against the son. The Court also ordered deletion from the High Court record of a disparaging observation which had been made about the son without giving him notice.

Case No.: CRIMINAL APPEAL NO.367 OF 2025 (@ SPECIAL LEAVE PETITION (CRIMINAL) NO.5896 OF 2023)
Case Title: Marippan & Anr. v. State represented by the Inspector of Police & Anr.
Appearances: (List advocates if available, for both sides)
For the Petitioner(s): Mr. Avinash Wadhwani, Advocate; Mr. G. Balaji, Advocate-on-Record; Mr. Neeleshwar Pavani, Advocate
For the Respondent(s): Mr. Amit Anand Tiwari, Sr. A.A.G.; Mr. Sabarish Subramanian, Advocate-on-Record; Ms. Devyani Gupta, Advocate; Ms. Arjoo Rawat, Advocate; Mr. Vishnu Unnikrishnan, Advocate; Mr. Danish Saifi, Advocate; Mr. A. Renganath, Advocate; Mr. R. Ayyam Perumal, Advocate-on-Record.