Naresh Aneja @ Naresh Kumar Aneja Vs. State of Uttar Pradesh & Anr. [Criminal Appeal No._______ of 2025 arising out of SLP (Crl.) No. 1093 of 2021]
- ByPravleen Kaur --
- 15 Jun 2025 --
- 0 Comments
The Supreme Court of India, in Naresh Aneja @ Naresh Kumar Aneja vs. State of Uttar Pradesh & Anr. [Criminal Appeal No. _______ of 2025 arising out of SLP (Crl.) No. 1093 of 2021], delivered its judgment on January 2, 2025, quashing the criminal proceedings against the appellant under Sections 354 (outraging the modesty of a woman) and 506 (criminal intimidation) of the Indian Penal Code (IPC).
Facts
Naresh Aneja and respondent Pooja Tankha were directors in a joint company, M/s LAJ-IDS Exports Pvt. Ltd., holding shares in a 3:1 ratio. Disputes arose between them concerning company management and finances. Pooja Tankha filed a complaint alleging that Aneja’s brother had physically harassed and threatened her, and that Aneja failed to act on her complaints. Subsequently, criminal proceedings were initiated against Aneja under Sections 354 and 506 IPC.
Legal Issues
The key issue was whether the allegations against Aneja met the prima facie threshold to sustain criminal proceedings or whether the charges should be quashed under the inherent powers of the High Court under Section 482 of the Criminal Procedure Code (CrPC).
Supreme Court’s Analysis
The Court emphasized that for an offence under Section 354 IPC, it is essential to prove the use of criminal force with the intent to outrage a woman’s modesty. The Court found no evidence on record indicating any such use of force or acts substantiating the allegations against Aneja. The FIR and charge sheet contained vague and uncorroborated assertions without material evidence like eyewitness accounts or CCTV footage.
Regarding Section 506 IPC, criminal intimidation requires clear intent to cause alarm or fear. The Court observed that the allegations were general and lacked tangible proof demonstrating such intent by Aneja.
The Court reiterated that while exercising powers under Section 482 CrPC, it is not to conduct a detailed trial but to assess if a prima facie case exists. Here, the evidence failed even to meet this threshold.
Conclusion
The Supreme Court allowed the appeal and quashed the criminal proceedings against Naresh Aneja, holding that the allegations were unsupported and did not justify a trial. The Court clarified that this decision was limited to Aneja and did not affect ongoing proceedings against other accused persons.
This judgment underscores the necessity of a clear and substantiated prima facie case before permitting criminal trials under Sections 354 and 506 IPC, preventing misuse of the criminal justice system through unsubstantiated allegations.
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