Karnataka HC Quashes Dhaba Bonded-Labour Case, Citing Victim’s Statement That He Was Not Confined

The petitioners, Accused Nos. 1–4, sought to quash proceedings in C.C. No. 1658/2025 arising from Crime No. 233/2024, alleging offences under Sections 115(2), 127(4) and 3(5) of the Bharatiya Nyaya Sanhita, 2023, and Sections 16, 17 and 18 of the Bonded Labour System (Abolition) Act, 1976.

The prosecution alleged that Accused Nos. 1 and 2 owned a dhaba where two workers were confined after one worker’s father borrowed ₹1,00,000; one worker was allegedly chained to a cot.

After investigation, police filed a charge sheet. The petitioners relied on the workers’ statements recorded under Section 164 Cr.P.C., which they said denied assault or confinement and described the dhaba owner favourably. The State opposed quashing, relying on the charge-sheet material and the possibility of pressure on the witnesses.

The petition invoked the High Court’s inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973, corresponding to Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, to seek quashing of the proceedings.

The Court stated that it could exercise its inherent jurisdiction to quash proceedings in order to secure the ends of justice where, on the material before it, requiring the accused to face trial would serve no purpose.

The Court considered the charge-sheet statements and the Section 164 Cr.P.C. statements, which it understood as indicating that no incident of assault or confinement had occurred and that the accused were good persons.

On that basis, it concluded that requiring the petitioners to face trial would serve no purpose and that quashing the proceedings was appropriate to secure the ends of justice. The order does not separately analyse the State’s submission that the witnesses might have been pressured.

The pending interlocutory application was also disposed of.