The Supreme Court has strongly criticized inconsistent judicial decisions delivered by different benches of the same court, stating that such actions harm the integrity of the judicial system and turn litigation into a “punter's game.” This came in the case Renuka v. State of Karnataka and Anr., where the apex court set aside an order of the Karnataka High Court that had quashed domestic violence proceedings against the husband.
The appeal was filed by the complainant-wife, Renuka, challenging the High Court’s decision to quash criminal charges against her husband, despite a previous coordinate bench allowing proceedings against other in-laws in the same matter.
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The bench of Justices P.S. Narasimha and Justice Joymalya Bagchi held that the High Court had failed to maintain judicial discipline.
“Consistency in judicial outcomes is the hallmark of a responsible judiciary. Inconsistent decisions coming out from different benches shake public trust and reduce litigation to a punter’s game,” the Court observed.
The case stemmed from a 2021 complaint in which Renuka accused her husband and in-laws of harassment, dowry demands, and physical assault, including an incident where chilli powder was thrown in her eyes. The complaint led to a criminal case under Sections 498-A, 324, 355, 504, 506 read with Section 149 of the IPC.
Initially, the High Court allowed the case to proceed against most of the in-laws, except for the elderly parents-in-law. Later, a separate judge of the same High Court quashed the charges against the husband without even mentioning the earlier order.
“Though the order refusing to quash the proceeding against some of the in-laws was passed earlier, it is inexplicable why there is no reference to the said order in the impugned order,” said Justice Bagchi.
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The Supreme Court stressed that coordinate benches—benches of equal strength—must follow earlier decisions or clearly explain why they are departing from them. Ignoring this principle, known as stare decisis, amounts to judicial arbitrariness and undermines public confidence in the system.
The Court also pointed out that the High Court had wrongly ventured into evaluating the credibility of the complaint and medical evidence at the quashing stage—something that should be done during trial.
“It was unwarranted for the judge to embark on a mini-trial... Whether ocular evidence is fully incompatible with medical evidence is a matter of trial,” the Court added.
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Justice Bagchi's judgment emphasized that the presence of a matrimonial dispute does not automatically make a criminal complaint an abuse of the legal process, especially when it is supported by independent witnesses and medical proof.
The Court concluded that the High Court's order was based on arbitrary reasoning, ignored binding precedents, and failed to respect judicial consistency. Accordingly, it reinstated the criminal proceedings against the husband and allowed the appeal.
Appearance:
For Petitioner(s) : Ms. Rudrali Patil, Adv. [arguing counsel] Mr. Shaantanu Devansh, Adv. Mr. Suhas Hosamani, Adv. Ms. Rushika Patil, Adv. Mr. Sabeel Ahmed, Adv. Mr. Anshuman, AOR
For Respondent(s) : Mr. D. L. Chidananda, AOR [arguing counsel] Mr. Anand Sanjay M Nuli, Sr. Adv. M/S. Nuli & Nuli, AOR Mr. Abhishek Kanyalur, Adv. Mr. Abhishekh Singh, Adv.
