The Supreme Court on Tuesday highlighted the erosion of public trust caused by inconsistent decisions from different benches of the same court, emphasizing that consistency is the hallmark of a responsible judiciary.
A bench comprising Justice P.S. Narasimha and Justice Joymalya Bagchi was hearing a matrimonial dispute where two single-judge benches of the Karnataka High Court had passed contradictory orders. While one judge declined to quash proceedings against the in-laws—citing a wound certificate indicating the complainant had suffered assault and sustained injuries—another judge, in a separate order, quashed the case against the husband.
The latter held that the medical evidence did not support the allegations, as the injuries described were inconsistent with assault by a blunt weapon.
Authoring the judgment, Justice Bagchi criticized the second order, noting that the judge had erred by engaging in a mini-trial at the stage of quashing, which is impermissible in law. “The judge misdirected himself by assessing the credibility of the FIR allegations in light of the medical certificate, effectively conducting a preliminary trial,” the Court observed.
The bench also found it inexplicable that the second judge failed to consider or refer to the earlier order refusing to quash proceedings against the in-laws. “Judicial propriety required the judge to acknowledge the coordinate bench’s decision and provide reasons for deviating from it,” the Court held, adding that such omissions breach judicial discipline.
The Court warned that inconsistent rulings can lead to forum shopping and undermine the credibility of the justice system. “Inconsistent decisions from coordinate benches shake public confidence and reduce the legal process to a gamble,” it noted.
The apex court further rejected the High Court’s reasoning that the criminal case amounted to abuse of process merely because matrimonial proceedings were ongoing. “Offences involving cruelty to a wife often arise from matrimonial discord. The pendency of a family court case does not by itself render criminal allegations malicious, especially when supported by medical evidence and independent witnesses,” the bench clarified.
The Court also observed that the wound certificate did note injuries, and it was no one’s case that the allegations were patently false or inherently improbable. “Whether the medical evidence corroborates or contradicts the eyewitness account is a matter for trial—not a ground for quashing at the threshold,” it added.
The top court passed its order while allowing the wife’s appeal against the High Court's decision to quash criminal proceedings against her estranged husband. She had accused him of having an extramarital affair, subjecting her to verbal abuse, physical and mental cruelty, and demanding ₹2 lakh as dowry. Following the alleged abuse, she had moved back in with her parents and filed an FIR against her husband and in-laws.
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