Supreme Court Quashes Chargesheet for Offences under Sections 269, 270, and 504 IPC in Workplace Dispute: B.V. Ram Kumar vs. State of Telangana (2025)

Introduction

Date of the Judgment: February 10, 2025

Citation: 2025 INSC 194

Judges: Justice Sanjiv Khanna, Justice Sandeep Mehta

Can a superior’s reprimand in the workplace amount to criminal intimidation? The Supreme Court of India addressed this question in the case of B.V. Ram Kumar vs. State of Telangana, where an appeal was filed against the High Court’s decision regarding a chargesheet filed under Sections 269, 270, and 504 of the Indian Penal Code (IPC). The core issue revolved around whether the chargesheet disclosed offences that warranted prosecution. The judgment was delivered by a two-judge bench comprising Justice Sanjiv Khanna and Justice Sandeep Mehta.

Case Background

The case originated from a complaint filed by Respondent No. 2, an Assistant Professor at the National Institute for Empowerment of Persons with Intellectual Disabilities, Secunderabad. On February 2, 2022, she was called to the chamber of the appellant, B.V. Ram Kumar, who was the Officiating Director of the Institute. The complainant alleged that Ram Kumar reprimanded her in a high-pitched voice for filing complaints against him. She protested, citing her recent recovery from COVID-19 and ongoing medical issues, and stated that she would submit a written reply. Following this incident, she filed a complaint, leading to an FIR registered on February 5, 2022, at Police Station, Bowenpalli, Hyderabad, under Sections 269, 270, 504, and 354 IPC. The chargesheet, submitted on September 27, 2022, accused Ram Kumar of failing to provide adequate PPE kits and gloves, posing a risk of spreading infectious diseases. The trial court took cognizance and summoned the appellant, who then sought quashment of the chargesheet before the High Court, which was dismissed on May 3, 2024.

Timeline

Course of Proceedings

The appellant, aggrieved by the chargesheet and the cognizance taken by the trial court, filed a criminal petition under Section 482 of the Code of Criminal Procedure (CrPC) before the High Court, seeking to quash the proceedings. The High Court dismissed the petition, stating that the allegations against the appellant were serious and required a trial to elicit the true facts. This dismissal led to the appeal before the Supreme Court.

Legal Framework

• Section 269, IPC: This section deals with negligent acts likely to spread infection of disease dangerous to life. It states: “Whoever unlawfully or negligently does any act which is, and which he knows or has reason to believe to be, likely to spread the infection of any disease dangerous to life, shall be punished with imprisonment of either description for a term which may extend to six months, or with fine, or with both.”
• Section 270, IPC: This section pertains to malignant acts likely to spread infection of disease dangerous to life. It states: “Whoever malignantly does any act which is, and which he knows or has reason to believe to be, likely to spread the infection of any disease dangerous to life, shall be punished with imprisonment of either description for a term which may extend to two years, or with fine, or with both.”
• Section 504, IPC: This section addresses intentional insult with intent to provoke breach of the peace. It states: “Whoever intentionally insults, and thereby gives provocation to any person, intending or knowing it to be likely that such provocation will cause him to break the public peace, or to commit any other offence, shall be punished with imprisonment of either description for a term which may extend to two years, or with fine, or with both.”

Arguments

Appellant’s Submissions:

• The proceedings were initiated with malicious intent and ulterior motives, constituting an abuse of the legal process.
• Even if the allegations in the FIR and chargesheet are accepted at face value, they do not constitute the offences charged.
• The alleged act of speaking brusquely was without mens rea, as it was merely a query about the complainant’s work performance.
• Similar complaints made by the complainant to the Ministry were closed after the appellant’s reply.
• The chargesheet lacks fundamental facts and material to constitute the necessary ingredients of the offences.

Respondents’ Submissions:

• The High Court was justified in dismissing the quashing petition as it was without merit.
• The FIR and chargesheet make out a prima facie case of continuous harassment of the complainant.
• The appellant was in the habit of maltreating the complainant before clients and other staff.
• Witnesses supported the complainant’s version of the verbal altercation.
• The appellant’s failure to maintain adequate supplies of PPE kits, masks, and sanitizers constitutes offences under the charged sections.

Issues Framed by the Supreme Court

1. Whether the allegations in the chargesheet constitute offences under Sections 269, 270, and 504 of the Indian Penal Code (IPC).

Treatment of the Issue by the Court

Authorities

Cases Relied Upon:

• State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335 (Supreme Court of India): This case was cited to establish the principle that constitutional courts can quash criminal proceedings to prevent abuse of process or to secure the ends of justice if the allegations do not disclose the commission of any offence or make out a prima facie case against the accused.
• Fiona Shrikhande v. State of Maharashtra, (2013) 14 SCC 44 (Supreme Court of India): This case was referenced to discuss the essential ingredients of Section 504 IPC, emphasizing the need for intentional insult with the intent to provoke breach of the peace.
• Mohammad Wajid v. State of U.P., 2023 SCC Online SC 951 (Supreme Court of India): This case was cited to define the test for determining when abusive language constitutes an intentional insult under Section 504 IPC.

Legal Provisions Considered:

• Section 269, IPC: Negligent act likely to spread infection of disease dangerous to life.
• Section 270, IPC: Malignant act likely to spread infection of disease dangerous to life.
• Section 504, IPC: Intentional insult with intent to provoke breach of the peace.
• Section 482, CrPC: Inherent powers of the High Court.

Judgment

• State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335: The court relied on this authority to emphasize that criminal proceedings can be quashed if the allegations do not disclose the commission of any offence or make out a prima facie case against the accused.
• Fiona Shrikhande v. State of Maharashtra, (2013) 14 SCC 44: The court used this authority to define the essential ingredients of Section 504 IPC, emphasizing the need for intentional insult with the intent to provoke breach of the peace.
• Mohammad Wajid v. State of U.P., 2023 SCC Online SC 951: This case was cited to establish the test for determining when abusive language constitutes an intentional insult under Section 504 IPC, noting that mere abuse, discourtesy, rudeness, or insolence does not amount to an intentional insult.

What Weighed in the Mind of the Court?

The Supreme Court’s decision to quash the chargesheet was primarily influenced by the following considerations:

• The allegations in the chargesheet were conjectural and did not meet the necessary ingredients of the offences under Sections 269, 270, and 504 IPC.
• A superior’s reprimand, related to workplace discipline, does not constitute an intentional insult.
• Witnesses refuted the allegation of inadequate PPE supplies.
• Maintaining discipline in the workplace is essential, and allowing criminal charges against a Director for trying to maintain discipline could have disastrous consequences.

Logical Reasoning

The Supreme Court’s logical reasoning can be summarized as follows:

Allegations in Chargesheet → Assessment of Ingredients for Offences → Evaluation of Intentional Insult → Consideration of Workplace Discipline → Conclusion: Chargesheet Quashed

Key Takeaways

• A superior’s reprimand, related to workplace discipline, does not constitute an intentional insult under Section 504 IPC.
• Criminal charges against individuals for trying to maintain discipline in the workplace should be carefully scrutinized.
• Allegations must meet the necessary ingredients of the offences charged to warrant prosecution.

Directions

No specific directions were given by the Supreme Court in this judgment.

Development of Law

The ratio decidendi of the case is that a superior’s reprimand, related to workplace discipline, does not constitute an intentional insult under Section 504 IPC. This judgment reinforces the importance of maintaining discipline in the workplace and clarifies the scope of Section 504 IPC in such contexts.

Conclusion

In B.V. Ram Kumar vs. State of Telangana, the Supreme Court quashed the chargesheet filed against the appellant under Sections 269, 270, and 504 IPC, holding that the allegations were conjectural and did not meet the necessary ingredients of the offences charged. The court emphasized the importance of maintaining discipline in the workplace and clarified that a superior’s reprimand, related to workplace discipline, does not constitute an intentional insult.