### Reporting Contents of Police Complaint Verified by FIR Does Not Constitute Criminal Defamation Under Exception 8 Section 499 IPC.

The Petitioner, a Director of Godfrey Philips India Ltd. (GPIL), alleged that on 30.05.2024, he was assaulted and suffered a fracture while attempting to enter a board meeting.

He lodged a police complaint on 31.05.2024, leading to the registration of FIR No. 219/2024.

On 01.06.2024, The Economic Times published articles regarding the incident, which included a verbatim quote from the Petitioner’s police complaint: “My mother and Mr. Bhasin orchestrated this assault and the other present board members were consenting parties to this assault”.

The Respondents (Board Members) filed criminal defamation complaints under Sections 499/500 IPC, alleging this statement harmed their reputation.

The Magistrate initially dismissed the complaints under Section 203 Cr.P.C., but the Sessions Court reversed this in revision and directed summoning of the Petitioner.

The Petitioner challenged the summoning orders before the High Court.

1. Whether the verbatim reproduction of a statement made in a police complaint/FIR in a news report constitutes the offense of defamation under Section 499 IPC.

2. Whether the Petitioner is entitled to the protection of Exception 8 to Section 499 IPC at the summoning stage.

Section 499 of the Indian Penal Code (IPC), specifically Exception 8, which protects accusations made in good faith to an authorized person for lawful redressal.

Principle from Iveco Magirus Brandschutztechnik GmbH v. Nirmal Kishore Bhartiya [2023 SCC OnLine SC 1258], establishing that a Magistrate can apply IPC Exceptions at the summoning stage if the material reveals a complete defense.

Principle from Vijay v. Ravindra Ghisulal Gupta [2022 SCC OnLine Bom 1315] and Mahadev I. Todale v. Frankfinn Aviation Services Pvt. Ltd. [2017 SCC OnLine Del 9135], holding that the faithful reporting of the contents of an FIR or police complaint without embellishment does not constitute defamation.

The Court observed that the Respondents’ grievance was restricted to a single sentence in the news articles which was a verbatim reproduction of the Petitioner’s written complaint to the Sarita Vihar Police Station.

The Court found that the news article used double quotation marks and clearly attributed the content to the formal "complaint" rather than an independent interview statement.

The Court reasoned that since the statement was made to a lawful authority (the police) to set criminal law in motion (resulting in an FIR and charge-sheet), it was protected by Exception 8 of Section 499 IPC.

The Court emphasized that allowing defamation proceedings for statements made in an FIR, which are subsequently reported by the media without distortion, would result in stifling legitimate criminal grievances and creating an unnecessary "parallel trial".

The High Court set aside the Sessions Court’s orders dated 14.08.2025 and the Magistrate’s summoning order dated 18.08.2025, effectively quashing the defamation proceedings.