Reported Judgments of Nagaraj Ravikumar
Below is our comprehensive catalogue of judgments divided between High Court rulings and City/Civil & Sessions Court orders. Each entry includes the case name, citation, court & date, a concise summary, and a link to download the full PDF.
High Court
Karnataka High Court Refuses to Quash FIR Against Husband in Dowry Harassment Case, Grants Relief to In-Laws
The Karnataka High Court, in its recent judgment, delivered an important decision on the scope of criminal liability of in-laws in dowry harassment cases. Justice M. Nagaprasanna allowed, in-part a petition filed by the husband, mother-in-law, and father-in-law, challenging the registration of an FIR under the Bharatiya Nyaya Sanhita, 2023 (BNS) and the Dowry Prohibition Act, 1961.
Background of the Case
The complainant (wife) had lodged a complaint in December 2024, leading to registration of FIR against her husband and in-laws. She alleged physical and mental cruelty, demand of dowry, and various forms of harassment during her short-lived marriage. The offences invoked included Sections 115(2), 351(3), 352 and 85 of the BNS, along with Sections 3 and 4 of the Dowry Prohibition Act.
The husband and his parents approached the High Court seeking quashing of the FIR, contending that the complaint was frivolous and based on trivialities.
The petitioners (husband and his parents) contented that the complaint was frivolous and unsustainable in law. It was contended that the allegations did not disclose the ingredients of cruelty or dowry demand. The accusations against the husband, according to them, were exaggerated, mentioning matters such as his indulgence in cricket betting, playing games like Ludo, and even treating the family’s pet cat better than his wife. It was further argued that the mother-in-law and father-in-law were unnecessarily dragged into the proceedings without any specific allegations attributed to them. The petitioners maintained that the FIR amounted to an abuse of process of law and sought its quashing in entirety.
Counsel for the complainant-wife strongly opposed the petition, asserting that the complaint contained detailed allegations of cruelty and harassment, while highlighting specific instances of physical violence, including an incident that led to the complainant’s hospitalization, supported by a discharge summary and medical records indicating wrist injuries caused by assault. The respondent also placed reliance on WhatsApp chats to show the husband’s abusive conduct and his alleged relationships outside marriage.
Taking into account the detailed complaint, the WhatsApp chats, and the medical records, the Court held that the allegations against the husband disclosed the ingredients of cruelty and voluntarily causing hurt under the Bharatiya Nyaya Sanhita. It therefore refused to quash the FIR as against him.
Justice M. Nagaprasanna observed that “Insofar as 1st petitioner/husband is concerned, it is for him to face investigation and come out clean in a full-blown trial, as the allegations against him undoubtedly meet ingredients of every offence alleged.”
At the same time, the Court, while placing reliance on the judgements of the Supreme Court of India, held that the omnibus allegations against the mother-in-law and father-in-law did not make out offences under the provisions invoked, and continuing proceedings against them would amount to abuse of process. Accordingly, the FIR was quashed only insofar as they were concerned.
The Decision
The Court partially quashed the FIR, and the proceedings will continue against the husband. Whereas, the proceedings against the mother-in-law and father-in-law were quashed.
Karnataka HC first judgement on black magic act, “Plain and Simple Marital Discord Dressed with Black Magic” Karnataka HC Quashes FIR; Clears Mother-in-law in Dowry Case.
In a reported judgment passed by Hon’ble Mr. Justice M. Nagaprasanna, in July 2024, delivered a common order on a Criminal Petition and two Writ Petitions. The cases involved allegations of dowry harassment, theft, attempted murder, and practices under the Karnataka Prevention and Eradication of Inhuman Evil Practices and Black Magic Act, 2017.
Brief Background of the Cases:
The disputes began with the wife filing a complaint alleging dowry harassment and cruelty by her husband and mother-in-law under Sections 498A and 323 read with Section 34 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act, 1961. Following investigation, a charge sheet was filed against the husband and mother-in-law for offenses under Sections 498A, 504, read with Section 34 of the IPC and Sections 3 and 4 of the 1961 Act. The husband and mother-in-law challenged these proceedings in a Criminal Petition before the High Court of Karnataka.
Subsequently, the husband filed a private complaint against the wife. This complaint led to the registration of a criminal case for offenses under Sections 380, 411, 506, 307, 511, and 34 of the IPC and Section 3 of the Karnataka Prevention and Eradication of Inhuman Evil Practices and Black Magic Act, 2017. The allegations included theft and attempted murder (allegedly through black magic). The Wife approached the High Court of Karnataka seeking to quash the said proceedings.
Court’s Analysis and Decision:
Hon’ble Justice Nagaprasanna observed that while the complaint and charge sheet did not indicate specific offenses against the mother-in-law, there were clear allegations and ingredients of offenses against the husband. Citing the Supreme Court’s judgment in KAHKASHAN KAUSAR v. STATE OF BIHAR, which cautioned against implicating relatives based on general and omnibus allegations in matrimonial disputes, the court quashed the proceedings against the mother-in-law. However, the court held that the husband would have to face a trial due to the serious allegations against him, and thus dismissed the petition concerning him.
Turning to the writ petition filed by the wife, represented by Advocate Mr Nagaraj Ravikumar, challenging the case involving theft, attempted murder, and black magic, the court concluded that the husband’s complaint was a “counter-blast” to the case registered by the wife. The court noted the significant delay (in years) in complaining about the alleged thefts.
Crucially, the court examined the allegations related to attempted murder through black magic and the applicability of the Black Magic Act, and noted them to be “completely vague” and lacking any ingredients that would constitute an offense under the Black Magic Act. The court emphasized that there was no act performed, nor an attempt to perform any of the ingredients listed in the Schedule.
The court further found that the allegations related to theft and attempted murder under the IPC also lacked the necessary ingredients. The court stated that a “plain and simple marital discord is dressed with black magic, theft, and attempt to murder.”
The court concluded that allowing the criminal case to continue would amount to an abuse of the process of law and result in patent injustice.
Conclusion: The court allowed the writ petition filed by the wife, quashing the FIR in its entirety.
Karnataka HC Orders Speedy Disposal of Suit, Noting Alleged Delay by Plaintiffs and Senior Citizen Defendant
The High Court of Karnataka, in its judgment in April 2025, directed the District and Sessions Court (Trial Court), Bengaluru, to hear and dispose of a Suit filed in the year 2018 within a year. The petitioners, represented by Advocate Mr. Nagaraj Ravikumar, sought expeditious disposal of the suit before the Trial Court and contended that the plaintiffs in the suit were delaying the proceedings by seeking adjournments.
The court, presided over by the Hon’ble Mr Justice H.T. Narendra Prasad, noted that issues had been framed and the matter was posted for the plaintiffs’ evidence, taking into account that the petitioner was a senior citizen. Without expressing an opinion on the merits, the court directed the Trial Court to dispose of the suit in accordance with law and as expeditiously as possible, but not later than one year from the date of receipt of the order.
With this direction, the writ petition was disposed of.
City, Civil & Sessions Courts
Accident or Intent to Kill? Bengaluru Court Grants Bail in Attempted Murder, Rash Driving Case;
Bangalore District Court in February 2023 granted bail under Section 439 of the Criminal Procedure Code (Cr.P.C.) to the accused represented by Advocate Mr. Nagaraj Ravikumar, in connection with a criminal case registered by the Govindarajanagar Police Station. The case involved alleged offenses under Sections 337, 338, and 307 of the Indian Penal Code (IPC).
The scooter rider allegedly attempted to flee the scene of the accident while the victim held onto the back stand of the scooter. The rider allegedly continued to drive at speed, dragging the victim for about 500-600 meters, who sustained injuries to the legs, knee, and back.
It was argued that the offenses under Sections 337 and 338 are not heinous and that the Accused had no intention to harm the complainant.
The court considered the arguments and evidence presented, while referring to citations from the Hon’ble High Court of Karnataka and the Hon’ble Supreme Court (1978) 1 SCC 118, the court emphasized the factors to be considered when granting bail under Section 439 of Cr.P.C., including the nature and gravity of the offense, the likelihood of the accused absconding or tampering with witnesses, and the character and standing of the accused. The court found that the present case’s facts and circumstances aligned with those discussed in the cited judgments, that “bail is a rule, jail is the exception,” and the court granted bail to the accused, subject to the imposed conditions.
Bail Granted by Bengaluru Rural Court in NDPS Case with 2.595 kg Ganja Seizure
Special Court (NDPS), Bengaluru Rural District, granted regular bail to an accused in a case registered under the Narcotic Drugs and Psychotropic Substances (NDPS) Act, 1985, in January 2025.
The petitioner/accused represented by Advocate Mr Nagaraj Ravikumar was arrested in connection with a Criminal complaint registered by the Electronic City Police Station for an offence under Section 20(b)(ii)(B) of the NDPS Act. The prosecution alleged that the accused was found selling ganja. During a raid, 2 Kgs and 595 grams of ganja were seized from the Accused’s possession.
It was argued that the quantity of ganja seized, noting that 2 Kgs and 595 grams falls under the category of “intermediate quantity” as per the Ministry of Finance Department of Revenue Notification S.O.1055(E) dated October 19, 2001. The notification specifies that 1000 grams is considered a small quantity and 20 kg is a commercial quantity for ganja.
The court, placing reliance on the Hon’ble Apex Court decision in Birbal Prasad Vs., State of Bihar (2018 11 SCC 488), where bail was granted for a non-commercial quantity of 14 Kgs of ganja, observed that when the seized quantity is less than the commercial quantity, the stringent provisions of Section 37 of the NDPS Act are not attracted, and the factors for granting bail are similar to those under regular statutes, unless exceptional circumstances are shown by the prosecution.
The court also noted that the stage of the case is still under investigation, and the alleged offence is not punishable with death or life imprisonment. Custodial interrogation was deemed not warranted as the petitioner’s voluntary statement had already been recorded. The court also took into account the petitioner’s permanent address and imposed stringent conditions to address the prosecution’s apprehension of the petitioner absconding or protracting the trial.
Accordingly, the petition filed under Section 483 of BNSS was allowed, subject to compliance with bail conditions.