Man Clinging To Moving Car’s Bonnet In Bengaluru Road-Rage Clash: Karnataka HC Quashes Both FIRs, Finds Alleged Offences Not Made Out

In brief

The question

1. Whether the allegations in the two FIRs disclosed the ingredients of the offences charged under the BNS.

The court held

The Court allowed all three petitions and quashed Crime No. 60/2026 against Suresh and Crime No. 63/2026 against Nanjunda and Manoj, both pending before the X Additional Chief Judicial Magistrate, Bengaluru City.

01Facts

On 11 February 2026, following a road incident in Bengaluru, Nanjunda alleged that Suresh drove his car forward while Nanjunda was on its bonnet, and that Suresh had abused him.

pp. 6–8

Halasuru Police registered Crime No. 60/2026 against Suresh under Sections 109(1) and 352 of the Bharatiya Nyaya Sanhita, 2023 (BNS).

pp. 6–8

Sonia, Suresh’s wife, lodged a counter-complaint alleging that Nanjunda and Manoj had followed and obstructed their car, threatened and abused them, and that one of them had held onto the bonnet.

pp. 8–9, 12–13

Crime No. 63/2026 was registered against Nanjunda and Manoj under Sections 126(2), 351(2) and 352 BNS.

pp. 8–9, 12–13

Suresh, Nanjunda and Manoj each petitioned under Articles 226 and 227 of the Constitution and Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), seeking quashing of the respective FIRs.

pp. 1, 3–5

02Issues

i.1. Whether the allegations in the two FIRs disclosed the ingredients of the offences charged under the BNS.

pp. 9–10, 14

ii.2. Whether, in the circumstances of this cross-case arising from a single road-rage incident, continuation of the criminal proceedings would amount to an abuse of process warranting quashing under Section 528 BNSS.

pp. 14–16

03Law Applied

Section 528 BNSS preserves the High Court’s inherent jurisdiction to prevent abuse of the process of court and secure the ends of justice.

pp. 14–16

Relying on Anita Maurya v. State of Uttar Pradesh, 2026 SCC OnLine SC 1519, and the principles quoted from Mahmood Ali v. State of U.P. and Mohammad Wajid v. State of U.P., the Court stated that when mala fides or an ulterior motive is alleged, it may look beyond the FIR’s wording and consider the surrounding circumstances and material on record; it must do so carefully, without conducting a mini-trial or stifling a legitimate prosecution.

pp. 14–16

The Court also referred to the categories in State of Haryana v. Bhajan Lal concerning proceedings that disclose an abuse of process.

p. 16

Provisions in the judgment · 10 · Linked ones open on LawLens

Bharatiya Nagarik Suraksha Sanhita, 2023 Section 528

Bharatiya Nyaya Sanhita, 2023 Section 109 Section 352 Section 126 Section 351

Indian Penal Code, 1860 Section 307 Section 504 Section 341 Section 506

Code of Criminal Procedure, 1973 Section 482

04Reasoning

The Court considered the complaints together because both arose from the same incident and involved the same parties.

pp. 6–9, 14

It characterized the incident as road rage and, on examining both complaints and the surrounding circumstances, concluded that the ingredients of the offences alleged were not made out.

p. 14

Applying the quashing principles in Anita Maurya and the authorities quoted therein, the Court held that the circumstances justified exercising its inherent jurisdiction rather than allowing the cross-proceedings to continue.

pp. 14–16