Supreme Court Quashes Kidnapping Charges in Mafat Lal vs State of Rajasthan

The Supreme Court of India, in its judgment dated March 28, 2022, ruled on the case of Mafat Lal & Another vs The State of Rajasthan. The Court quashed the criminal proceedings against the appellant, recognizing that the alleged victim had willingly left her parental home and later married the accused.

Background of the Case

The case dates back to May 23, 2005, when an FIR No. 45 of 2005 was registered at Police Station Phulera, District Jaipur, under Sections 363 and 366 of the Indian Penal Code (IPC). The complaint was filed by Prahalad Dan, the father of the alleged victim, who accused the appellant, Mafat Lal, of abducting his minor daughter.

However, the appellant and the alleged victim later married in December 2006 and were living together happily with their child. The couple filed a petition under Section 482 of the Criminal Procedure Code (CrPC) before the Rajasthan High Court, seeking to quash the FIR and all related proceedings.

Petitioner’s Arguments (Mafat Lal & Another)

The appellants argued:

The alleged victim had willingly left her parental home due to a love affair with the appellant.
She was not abducted or coerced but left voluntarily because her father opposed their relationship.
They got married in December 2006 and have been living together happily.
The prosecution of this case served no purpose as nearly two decades had passed.
The Rajasthan High Court had erred in rejecting their petition by assuming that the accused had forcibly taken away the girl.

Respondent’s Arguments (State of Rajasthan)

The state government opposed the petition, arguing:

The victim was a minor (under 18 years) at the time of the incident.
The accused had evaded investigation for several years.
The case involved serious charges under Sections 363 (kidnapping) and 366 (kidnapping, abducting, or inducing a woman to compel marriage) of IPC.

Supreme Court’s Observations

The Supreme Court, comprising Justices S. Abdul Nazeer and Vikram Nath, ruled in favor of the petitioners and quashed the criminal proceedings.

On the Allegation of Kidnapping

The Court noted:

“Kidnapping would necessarily involve enticing or taking away any minor under eighteen years of age if a female for the offense under Section 363 IPC.”

However, in this case, the alleged victim had clearly stated that:

“She was neither taken away nor induced, and she had left her home on her own free will.”

On the Charge Under Section 366 IPC

The Court ruled that:

“Section 366 IPC would apply only where there is a forceful compulsion of marriage by kidnapping or inducing a woman. In this case, the victim herself has stated that she married the appellant of her own free will.”

On the Passage of Time

The Court recognized that:

“Almost 15 years have passed, the couple has been living happily, and they have a child. No useful purpose would be served by continuing the trial.”

Final Verdict

The Supreme Court ruled:

“The appeal is allowed. The impugned judgment of the High Court of Rajasthan is set aside, and the entire proceedings arising out of FIR No. 45 of 2005 dated 23.05.2005 registered with Police Station Phulera, District Jaipur, under Sections 363 and 366 IPC and all consequential proceedings are hereby quashed.”

Implications of the Judgment

This ruling establishes several important legal principles:

If a woman willingly leaves her home and later confirms that she was not coerced, kidnapping charges may not be sustained.
A long lapse of time and a subsequent marriage can be relevant factors in deciding whether to continue a trial.
Court intervention can prevent unnecessary criminal prosecution that serves no purpose.
Section 482 CrPC provides an effective remedy for quashing baseless criminal cases.

Conclusion

The Supreme Court’s ruling in Mafat Lal vs. State of Rajasthan reinforces the need to distinguish between genuine cases of kidnapping and situations where individuals willingly leave home due to personal relationships. The judgment upholds the right of individuals to make personal choices while preventing the misuse of kidnapping laws.

Petitioner Name: Mafat Lal & Another.
Respondent Name: The State of Rajasthan.
Judgment By: Justice S. Abdul Nazeer, Justice Vikram Nath.
Place Of Incident: Rajasthan.
Judgment Date: 28-03-2022.

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