Supreme Court Quashes Criminal Proceedings in Workplace Dispute image for SC Judgment dated 03-08-2023 in the case of Sunil Kumar vs State of U.P. & Anr.
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Supreme Court Quashes Criminal Proceedings in Workplace Dispute

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The Supreme Court of India recently ruled in favor of the appellant in Sunil Kumar v. State of U.P. & Anr., a case that stemmed from a minor workplace altercation. The Court quashed criminal proceedings against the appellant, stating that continuing the case would amount to unnecessary harassment.

Background of the Case

The case arose from an incident at the Uttar Pradesh Power Corporation Ltd., where the appellant, Sunil Kumar, worked as an Assistant Engineer and the complainant (Respondent No. 2) was a Peon in the same office.

The key events leading to the case were:

  • September 11, 2014: An altercation occurred between the appellant and Respondent No. 2 regarding the issuance of certain articles to a consumer. The appellant alleged that the complainant became aggressive, used abusive language, and attempted to assault him with a slipper.
  • September 12, 2014: In response, the complainant filed a counter-complaint alleging that the appellant had assaulted him, used abusive language, and threatened to kill him.
  • September 2014: The police registered two cross-complaints regarding the incident.
  • 2015: Following an investigation, a charge sheet was filed against the appellant under Sections 323 (voluntarily causing hurt), 504 (intentional insult), and 506 (criminal intimidation) of the Indian Penal Code (IPC).
  • 2015: The appellant moved the Allahabad High Court seeking to quash the charge sheet and the criminal proceedings.
  • March 13, 2018: The High Court dismissed the appellant’s plea, leading him to file an appeal before the Supreme Court.
  • August 3, 2023: The Supreme Court quashed the criminal proceedings, finding them to be unnecessary and trivial.

Key Legal Issues Considered

The Supreme Court examined the following questions:

  • Whether the allegations in the complaint were serious enough to warrant a criminal trial.
  • Whether the long delay in the case (since 2015) justified quashing the proceedings.
  • Whether the case should have been resolved within the workplace rather than through a criminal trial.

Arguments by the Appellant

The appellant, Sunil Kumar, contended:

  • The alleged offense was trivial and did not warrant prolonged litigation.
  • The complaint was a retaliatory act following his initial police complaint.
  • The criminal proceedings had caused him undue stress and professional hardship.
  • The case had been pending for nearly a decade with no trial progress.

Arguments by the Respondents

The State of Uttar Pradesh and Respondent No. 2 argued:

  • The complaint against the appellant was legitimate and should be decided in court.
  • Despite the delay, the legal process should be allowed to take its course.
  • Criminal proceedings serve as a deterrent against workplace misconduct.

Supreme Court’s Analysis and Judgment

1. Nature of the Allegations

The Court found that the allegations were of a minor nature:

“Considering the nature of allegations against the appellant, which are of very trivial nature, and considering the fact that there is no progress made in the proceedings since the charge sheet was filed against the appellant in the year 2015, the Court is of the opinion that continuing the proceedings would be a persecution and harassment to the appellant.”

2. Delay in Proceedings

The Court noted the excessive delay in the case:

“The said case is pending without trial since 2015 in the said court. As such a petty incident which took place in their office should have been resolved by the parties on that day itself, instead of stretching it so far.”

3. Workplace Disputes and Criminal Law

The Court emphasized that minor workplace disputes should not be escalated into criminal cases:

“As such a petty incident which took place in their office should have been resolved by the parties on that day itself, instead of stretching it so far.”

Supreme Court’s Final Decision

The Supreme Court quashed the criminal proceedings:

  • The case against the appellant was quashed and set aside.
  • The prolonged litigation was deemed unnecessary and unjustified.
  • The Court found that pursuing the case further would amount to harassment.

Conclusion

This ruling establishes important legal principles:

  • Trivial workplace disputes should be resolved internally: Not every minor altercation should lead to criminal charges.
  • Excessive delays can justify quashing cases: Courts should prevent prolonged legal harassment over minor issues.
  • Criminal law should not be misused for personal retaliation: Filing counter-complaints for minor workplace disagreements is discouraged.

This judgment serves as a precedent for how courts should handle minor disputes that escalate into criminal cases without sufficient grounds.


Petitioner Name: Sunil Kumar.
Respondent Name: State of U.P. & Anr..
Judgment By: Justice Sanjiv Khanna, Justice Bela M. Trivedi.
Place Of Incident: Fatehpur, Uttar Pradesh.
Judgment Date: 03-08-2023.

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