'Attempt to transform civil dispute into criminal matter': Supreme Court quashes workplace harassment case

New Delhi: The Supreme Court has quashed a criminal case lodged by a woman employee against senior officials of a company in Bengaluru, after she was told to resign as technical system analyst, noting that the proceedings were launched with mala fide intentions, to wreak vengeance, and coerce settlement.

A bench of Justices Dipankar Datta and Prashant Kumar Mishra allowed a plea by Madhushree Datta and Badrinarayana Jaganathan, then working as senior officials at Juniper Networks India Private Limited, Bengaluru.

After hearing senior advocate Sidharth Luthra for the appellants, the court set aside the Karnataka High Court's order of July 31, 2019, that had declined to quash the proceedings.

The counsel said the issues pertaining to resignation and termination are civil in nature, yet criminal proceedings have been initiated by the complainant solely to exert pressure and to gain an undue monetary advantage.

Luthra also contended the allegations in the FIR are so absurd and inherently improbable that no reasonable person could, based on these allegations, conclude that there are sufficient grounds to proceed against the appellants.

After a thorough examination of the matter, including a review of the materials on record, the complaint, the FIR, and charge sheet, the bench said, "We are of the view that none of the ingredients of Sections 323, 504, 506, and 509 of the IPC are present, even if they are taken at face value and accepted in their entirety. The complaint is bereft of even the basic facts, which are absolutely necessary for making out an offence."

The court noted the chargesheet stated that the appellants used "filthy language" while scolding the complainant; however, no such allegation was made against the appellants in the complaint.

"The term "filthy language," when examined in isolation, and without any contextual framework or accompanying words, indicating an intent to insult the complainant's modesty, does not fall within the purview of Section 509 of the IPC," the bench said.

The complainant first filed a non-cognisable report on October 26, 2013, alleging mental and physical harassment, after she was forcefully evicted from the office upon seizing the laptop.

More than two months later, an FIR was lodged by the complainant accusing the company of offences punishable under sections 323, 504, 506, 509, 511 IPC.

The bench, while noting discrepancies and variations, found, a deliberate attempt to reclassify the nature of the proceedings from non-cognisable to cognisable or to transform a civil dispute into a criminal matter, potentially aimed at pressurising the appellants into settling the dispute with the complainant.

"There are certain facts that strongly suggest that the criminal proceedings were initiated by the complainant against the appellants with mala fide intentions, specifically to wreak vengeance, cause harm, or coerce a settlement," the bench said in its judgment on January 24, 2025.

The bench also pointed out the presence of the second accused cannot by any stretch of imagination be visualised, if one were to barely read the complaints - initial and subsequent – and treat the contents as true, yet, the complainant alleged acts against him which, according to her, amounted to criminal offence.