Introduction:
In a significant ruling, the Karnataka High Court quashed criminal proceedings arising out of a road rage incident in Bengaluru that had escalated into cross complaints and charges of attempt to murder under the Bharatiya Nyaya Sanhita, 2023. The matter involved Indian Air Force officer Shiladitya Bose, his wife Madhumita (a Squadron Leader), and a call centre employee, Vikas Kumar S.J. The quarrel, which began as a heated exchange of words on the road, spiraled into criminal cases being filed against both parties after CCTV footage and viral videos drew public attention. However, when the matter reached the High Court, both sides admitted that the incident was merely verbal, that no physical injuries were sustained, and that they had resolved their differences amicably. Justice of the High Court, after carefully considering the submissions and affidavits, exercised inherent jurisdiction to quash the proceedings, observing that continuing with the trial would amount to an abuse of process of law.
Arguments of the Petitioners:
On behalf of Vikas Kumar, counsel argued that the dispute had arisen suddenly due to road rage and that his client never intended to assault or cause harm to the Air Force officer or his wife. He acknowledged before the Court that the incident consisted primarily of verbal altercations, with no evidence of physical assault. Kumar also clarified that he had not sustained any injuries during the exchange and had no objection to quashing the case registered against Bose. His position demonstrated his willingness to end the dispute rather than prolong unnecessary litigation, especially when the matter had already gained disproportionate public attention through viral videos. Kumar emphasized that pressing criminal charges of attempt to murder under Section 109 of the Bharatiya Nyaya Sanhita was excessive and disproportionate to the facts of the case, considering there was no violence or harm caused.
On behalf of Squadron Leader Madhumita Bose, it was argued that her initial complaint had been filed in the heat of the moment, based on her fear and perception during the incident. However, upon reflection and reconciliation, she realized that the altercation was verbal and did not result in any harm to her or her husband. She submitted that she had voluntarily chosen to withdraw the allegations and had no objection to the proceedings being quashed. Importantly, she confirmed that she had not suffered any injury and sought to avoid further litigation that could harm the reputation and career of her husband, a serving officer in the Indian Air Force.
For Air Force officer Shiladitya Bose, counsel stressed that he too had been a victim of the public narrative, where his video post alleging assault had gone viral. While Bose initially expressed grievance that the altercation was linked to language issues (allegedly being assaulted for not speaking Kannada), he later admitted before the Court that the matter was essentially a verbal quarrel arising out of road rage. He too expressed his willingness to close the chapter, recognizing that prolonging the matter would serve no useful purpose.
Arguments of the Respondent State:
The State, represented by HCGP M.R. Patil, highlighted that the FIRs had been registered based on the complaints and CCTV evidence, which prima facie suggested altercations between the parties. However, the State acknowledged that in criminal law, the cooperation and willingness of the complainants to pursue charges plays an important role, particularly when offences involve interpersonal disputes. While noting that offences like attempt to murder under Section 109 BNS are non-compoundable, the State left it to the Court’s discretion to determine whether, in the absence of injury and with the voluntary settlement by both parties, continuation of proceedings was warranted.
Court’s Judgment:
The Karnataka High Court carefully weighed the facts and submissions of both sides. The Court observed that although the case against Bose carried a charge under Section 109 (attempt to murder) of the Bharatiya Nyaya Sanhita, 2023, which is ordinarily non-compoundable, the peculiar circumstances of the case required a pragmatic approach. Justice noted that both complainants had voluntarily appeared before the Court, filed affidavits affirming that no injuries had been sustained, and expressed their willingness to end the dispute without pressing charges.
The Court emphasized that the inherent jurisdiction under Section 482 of the Code of Criminal Procedure (CrPC) allows the High Court to quash proceedings where continuation of a criminal case would amount to an abuse of the process of law or serve no useful purpose. It reiterated that courts must prevent the criminal justice system from being misused for personal grievances, particularly when the matter is trivial, settled amicably, and does not involve harm to public order or serious criminal conduct.
In its reasoning, the Court stated: “On consideration of the affidavits filed by the parties in both petitions, it is noticed that though the accused in Crime No.87/2025 is alleged to have committed an offence under Section 109 of the Bharatiya Nyaya Sanhita, 2023, which is otherwise non-compoundable, the presence of the complainant before this Court and his voluntary statement that no injuries were sustained, coupled with his willingness to give a quietus to the dispute, persuade this Court to exercise its inherent jurisdiction.”
The Court went on to add: “Continuation of proceedings in such circumstances would serve no fruitful purpose and would amount to an abuse of the process of law. This Court has also kept in mind the fact that one of the accused is a serving Air Force Officer, who would otherwise be compelled to face criminal proceedings for the aforesaid offences despite the matter being trivial and settled.”
Accordingly, the Court quashed both proceedings, allowing the petitions filed by Bose and Kumar. At the same time, it issued a stern warning to both parties, directing them not to indulge in such altercations in the future. The judgment highlighted that road rage, even when non-violent, can escalate into unnecessary disputes and criminal proceedings, and individuals must act responsibly in such situations.
The ruling carries wider significance as it illustrates the Court’s balanced approach in distinguishing between serious criminal conduct and trivial interpersonal disputes that do not merit continuation of criminal trials. It reinforces the principle that criminal law should not be used to punish momentary lapses or arguments where no harm is caused and where parties are willing to reconcile. The case also underscores the importance of judicial discretion in quashing proceedings to prevent abuse of law, especially when careers and reputations are at stake.