A complaint alleging assault may be dismissed where injury evidence is unrelated and alleged threats lack particulars.

The applicant alleged that respondents 2–5 assaulted and abused her on 15 March 2015, threatened her, and caused the loss of jewellery and documents.

After her efforts to have the police register a case were unsuccessful, she filed a complaint.

The Magistrate recorded her statement under Section 200 CrPC and a witness’s statement under Section 202 CrPC, but dismissed the complaint under Section 203 CrPC, finding that the dispute principally concerned land and that the complaint had been filed to exert pressure.

The Sessions Court dismissed her revision.

The applicant then sought relief under Section 482 CrPC.

The High Court noted that the medical document relied on by the applicant concerned a different person and a road accident in 2012, rather than the alleged 2015 incident.

1. Whether the Magistrate and Revisional Court erred in dismissing the complaint on the basis that the dispute was principally civil in nature and the alleged offences were not substantiated

2. Whether the impugned orders warranted interference under Section 482 CrPC

The Court considered Section 482 CrPC, which empowers the High Court to exercise its inherent jurisdiction, and Sections 200, 202 and 203 CrPC, governing examination of the complainant, inquiry or investigation at the pre-process stage, and dismissal of a complaint where sufficient ground for proceeding is absent.

No judicial precedent was cited. The Court’s decision rested on the complaint record and the absence of material supporting the alleged assault, threats, and abuses.

The Court found that the record contained no medical examination report relating to the alleged assault on 15 March 2015; the document filed was dated 20 November 2012, related to a road accident, and concerned another person.

The complaint also did not specify the alleged abuses or threats.

In light of these deficiencies, and the parties’ existing land litigation, the Court concluded that the lower courts had reasonably found insufficient support for the complaint and had properly dismissed it.

The Court also found that the applicant had attempted to mislead it by relying on the unrelated medical document.

It dismissed Criminal Misc. Application No. 419 of 2018.