Supreme Court dismisses plea seeking clarification on statements made during Habeas Corpus petition: Dhanlaxmi vs. State of Rajasthan (2025) INSC 196 (12 February 2025)

Introduction

Date of the Judgment: February 12, 2025
Citation: 2025 INSC 196
Judges: Justice Sudhanshu Dhulia, Justice Ahsanuddin Amanullah

When can a court refuse to entertain repeated requests for clarification on statements made during court proceedings? The Supreme Court of India, in the case of Smt. Dhanlaxmi Urf Sunita Mathuria & Anr. v. State of Rajasthan & Ors., addressed this issue. The petitioners sought clarification from the High Court regarding statements made by police officials during a Habeas Corpus petition concerning their mother’s alleged unlawful detention. The Supreme Court, comprising Justice Sudhanshu Dhulia and Justice Ahsanuddin Amanullah, dismissed the petition, finding it misconceived and unwarranted.

Case Background

The petitioners, Smt. Dhanlaxmi Urf Sunita Mathuria and another, filed a Habeas Corpus petition before the High Court of Rajasthan, alleging that their mother was in the unauthorized detention of private respondents. They also claimed that the police were unable to trace their mother despite the filing of missing person reports.

During the proceedings, police officials reportedly stated that a divorce decree had been passed between Petitioner No. 1 and her husband, and that her husband had remarried. Petitioner No. 1 requested the High Court to direct the police officials to clarify the veracity of these statements.

The High Court initially appeared to accept this request but ultimately dismissed the Habeas Corpus petition as infructuous on July 4, 2024, after the petitioners’ mother returned home.

Subsequently, the petitioners sought a review of the July 4, 2024 order, which was dismissed on July 23, 2024. Undeterred, they filed a miscellaneous application in August 2024, seeking a clarification from the police authorities regarding the basis of their statements about Petitioner No. 1’s divorce. This application was also dismissed, leading to the present appeal before the Supreme Court.

Timeline

Course of Proceedings

The petitioners initially filed a Habeas Corpus petition before the High Court of Rajasthan, alleging unlawful detention of their mother. During the hearing, statements were made by police officials regarding the marital status of Petitioner No. 1. The High Court dismissed the Habeas Corpus petition as infructuous after the mother returned home. Subsequent review and miscellaneous applications filed by the petitioners were also dismissed by the High Court, leading to the special leave petition before the Supreme Court.

Arguments

The petitioners, appearing in person before the Supreme Court, primarily argued that Petitioner No. 1 was humiliated and defamed in open court due to the statements made by the police officials regarding her matrimonial life. They contended that the High Court should have sought an explanation from the concerned police officials.

The petitioners claimed that the High Court had initially directed the police authorities to submit in writing the basis for their remarks, referring to an order dated May 30, 2024. However, the Supreme Court noted that the said order did not support this contention.

The Supreme Court observed that even if such statements were made, it was unable to understand how they caused any humiliation to Petitioner No. 1, emphasizing that court proceedings often involve uncomfortable questions aimed at reaching the truth.

Issues Framed by the Supreme Court

1. Whether the High Court was obligated to seek clarification from police officials regarding statements made during the Habeas Corpus petition.
2. Whether the statements made by the police officials caused humiliation and defamation to Petitioner No. 1.

Treatment of the Issue by the Court

Judgment

The Supreme Court dismissed the petition, stating that the petitioners’ grievances were misconceived. The Court held that even if the statements were made before the High Court, it was unable to understand how they caused any humiliation to Petitioner No. 1.

The Court emphasized that during court proceedings, many statements are made and questions are posed which may make a person uncomfortable, but such statements cannot be misconstrued as humiliating a person. The Court reiterated that its duty is to reach the truth, and this may demand putting forward certain questions and suggestions which may be uncomfortable to some.

The Court concluded that the Habeas Corpus petition was appropriately disposed of after the petitioners’ mother returned home, and subsequent petitions were unwarranted.

“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.”

“Thereafter, nothing was left in the matter and the subsequent review petition, miscellaneous application as well as the present petition filed by petitioners are totally misconceived.”

Key Takeaways

• ✓ Court proceedings may involve uncomfortable questions and statements, but these should not automatically be considered humiliating.
• ✓ Once a Habeas Corpus petition is resolved (e.g., the detained person returns), subsequent petitions on related matters may be deemed unwarranted.
• ✓ Litigants should avoid making unusual and unwarranted prayers before the Court.

Conclusion

The Supreme Court dismissed the petition filed by Smt. Dhanlaxmi Urf Sunita Mathuria and another, finding their grievances regarding statements made during a Habeas Corpus petition to be misconceived. The Court emphasized that statements made during court proceedings, even if uncomfortable, should not automatically be considered humiliating and that subsequent petitions after the resolution of the main issue were unwarranted.