The appeal was filed by Naresh Aneja, challenging a High Court decision that refused to quash a chargesheet and proceedings against him. The case originated from a complaint by a co-director, alleging workplace harassment and criminal intimidation, though the document also highlights a concurrent business dispute between the parties. The Supreme Court examined whether the allegations and evidence presented against Naresh Aneja sufficiently established the criminal offenses under sections 354 and 506 of the Indian Penal Code. Ultimately, the Court found that the prima facie ingredients of these offenses were not met for Naresh Aneja and quashed the criminal proceedings against him, while clarifying that the case against the other accused, R.K. Aneja, would continue.
(A) Criminal Procedure Code, 1973, Section 482 – Quashing of criminal proceedings – Offence u/s 354, 506 IPC – Held to apply Section 354 IPC, the offence must be committed against a woman; criminal force must be applied against her; and such application of force must be with the intent to outrage her modesty – The record is silent with respect to the use of any force, apart from bald assertions of mental and physical discomfort caused to the complainant by the appellant – For mens rea to be established, something better than vague statements must be produced before the court – As evidenced by the documents, i.e. the FIR, the preliminary investigation report as also the concluding portion of the chargesheet, no direct allegation nor any evidence in support thereof can be found attributing intent to the appellant – It cannot be said that a case u/s 354 IPC is made out against the appellant – Sum total of the circumstances, submissions and documents on record do not point to appellant having committed any offence against the complainant – Impugned judgment of the High Court passed in Application u/s 482 liable to be set aside – Criminal proceedings arising out of FIR No. liable to be quashed qua the present appellant.
(Para 12 to 17)
(B) Penal Code, 1860, Section 503, 506 – Criminal intimidation – Ingredients – For an offence u/s 503 to be established, it must be shown that: – (1) Threatening a person with any injury; (i) to his person, reputation or property; or (ii) to the person, or reputation of anyone in whom that person is interested. (2) Such threat must be intentional; (i) to cause alarm to that person; or (ii) to cause that person to do any act which he is not legally bound to do as the means of avoiding the execution of such threat; or (iii) to cause that person to omit to do any act which that person is legally entitled to do as the means of avoiding the execution of such threat – Punishment for this offence is prescribed u/s 506 IPC, which is two years or with a fine or both.
(Para 13)
Naresh Aneja @ Naresh Kumar Aneja V. State Of Uttar Pradesh
Supreme Court: 2025 INSC 19: (DoJ 02-01-2025)
