Quashing of Criminal Proceedings in Light of Subsequent Marriage: Mahesh Mukund Patel v. State of U.P.

Introduction

The Supreme Court of India, in Mahesh Mukund Patel v. State of U.P. & Ors., Criminal Appeal No. 001005/2025, quashed criminal proceedings against the appellant, citing the subsequent marriage between the appellant and the victim as a compelling reason to prevent undue harassment. This judgment reinforces the principle that criminal proceedings should not be pursued if they no longer serve the interests of justice.

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Background of the Case

The case originated from an FIR registered on September 18, 2016, under Sections 354A, 363, 366, and 376 of the Indian Penal Code, 1860 (IPC) and Sections 3 and 4 of the Protection of Children from Sexual Offences Act (POCSO Act). The complainant alleged that the victim, who was 17 years old at the time, was subjected to offenses of sexual assault and abduction by the appellant.

Subsequently, the appellant and the victim solemnized their marriage on December 5, 2016, as evidenced by a marriage certificate issued by the Registrar of Hindu Marriages, Varanasi. The victim’s date of birth, recorded in multiple official documents, was July 20, 1998, confirming that she was already a major at the time of the alleged offense. The couple also had two children together.

Supreme Court’s Reasoning

The Supreme Court found that:

1. Genuine Marriage and Family Life: The victim, now married to the appellant, expressed her willingness to stay with him, and they had built a family together.
2. Incorrect Age Consideration: The ossification test conducted during the investigation suggested the victim’s age was between 17½ to 19 years at the time of the incident, and documentary evidence confirmed she was a major.
3. Redundant Prosecution: Continuing the prosecution would serve no meaningful purpose and cause unnecessary harassment to the appellant, the victim, and their children.
4. Jurisdiction of High Court Under Section 482 CrPC: The High Court failed to exercise its inherent powers to quash the proceedings despite clear grounds for relief.

Based on these findings, the Supreme Court quashed the FIR and the Sessions Trial No. 1332/2021 pending before the Special Judge, POCSO Act, Varanasi.

Legal Implications

1. Application of Section 482 CrPC

This ruling reaffirms the power of the High Court under Section 482 of the Criminal Procedure Code (CrPC) to quash proceedings where justice demands it. The Supreme Court observed that the High Court should have exercised this power rather than directing the parties to the trial court.

2. Effect of Marriage on Criminal Proceeding

While marriage does not automatically nullify criminal liability, courts have consistently held that ongoing criminal prosecution should not disrupt a genuine marital relationship, particularly when the alleged victim herself seeks quashing of the case.

3. Age Determination in POCSO Cases

This case underscores the importance of documentary evidence over medical estimation when determining the age of a victim in POCSO cases. The court relied on official birth records rather than the ossification test results.

Conclusion

The Mahesh Mukund Patel case highlights the judiciary’s pragmatic approach in balancing legal technicalities with real-life implications. By quashing the proceedings, the Supreme Court protected the sanctity of marriage and family while preventing misuse of criminal law. This judgment sets a valuable precedent for similar cases where continued prosecution serves no meaningful purpose.

References:

1. Mahesh Mukund Patel v. State of U.P. & Ors., Criminal Appeal No. 001005/2025, Supreme Court of India.
2. Indian Penal Code, 1860.
3. Protection of Children from Sexual Offences Act, 2012.
4. Code of Criminal Procedure, 1973.