Summary

Smt. Dhanlaxmi Urf Sunita Mathuria & Anr. v. State of Rajasthan & Ors.

Citation: 2025 INSC 196
Court: Supreme Court of India
Judges: Sudhanshu Dhulia, J. & Ahsanuddin Amanullah, J.
Jurisdiction: Extraordinary Appellate – Special Leave Petition (Criminal)

HEADNOTES

1. Habeas Corpus – Petition Becomes Infructuous

• Held: A habeas corpus petition cannot be pursued once the alleged detained person returns home voluntarily.

2. Judicial Review – Scope of High Court’s Power

• Held: The High Court acted correctly in dismissing the habeas corpus petition as infructuous once the petitioners' mother returned home.

3. Police Statements in Court – Allegations of Humiliation

• Held: Statements made by police officials during court proceedings do not amount to humiliation or defamation, unless they are explicitly intended to malign the individual.

4. Misuse of Legal Remedies – Repeated Petitions Without Merit

• Held: Repeated filing of review petitions and miscellaneous applications on settled issues is an abuse of the judicial process and cannot be entertained.

FACTUAL BACKGROUND

• The petitioners filed a habeas corpus petition in the Rajasthan High Court, claiming that their mother was unlawfully detained by private respondents.

• While the petition was pending, the mother returned home voluntarily, leading to the High Court dismissing the petition as infructuous on 04.07.2024.

• The petitioners later alleged that police officials falsely claimed in court that Petitioner No. 1 was divorced and that her husband had remarried.

• The petitioners sought a review of the 04.07.2024 order, but the High Court dismissed it on 23.07.2024.

• A miscellaneous application was filed in August 2024, again requesting clarification from the police about their statements regarding the petitioner’s marital status.

• The High Court dismissed this application, leading to the present Special Leave Petition (SLP) before the Supreme Court.

LEGAL ISSUES

1. Whether a habeas corpus petition can continue after the alleged detained person returns home?

2. Whether police statements made in court about a petitioner’s personal life amount to defamation or humiliation?

3. Whether multiple petitions seeking review of a settled order amount to an abuse of judicial process?

COURT’S ANALYSIS

1. Habeas Corpus Petition Rightly Dismissed

   • The Supreme Court upheld that once the allegedly detained person returns, the habeas corpus petition loses its purpose.

   • The High Court was correct in dismissing the petition as infructuous.

2. Allegation of Humiliation – No Legal Basis

   • The petitioners claimed that the police’s remarks about the petitioner’s divorce caused humiliation and defamation in open court.

   • The Supreme Court ruled that statements made in court proceedings do not constitute defamation unless there is malicious intent.

   • The Court emphasized that uncomfortable questions or statements in judicial proceedings do not automatically amount to humiliation.

3. Repeated Petitions Are an Abuse of Process

   • The petitioners filed multiple applications despite the matter being concluded when their mother returned.

   • The Court ruled that filing review petitions and miscellaneous applications on a settled matter is an abuse of judicial process.

   • The Supreme Court dismissed the present petition as misconceived and unwarranted.

CONCLUSION & FINAL ORDER

1. The habeas corpus petition was rightly dismissed as infructuous by the High Court.

2. Statements made in court do not amount to defamation unless intended to malign the petitioner’s reputation.

3. Repeated filings by the petitioners were an abuse of process and cannot be entertained.

4. The Supreme Court dismissed the Special Leave Petition and all pending applications.

Final Disposition: Petition Dismissed

This case reinforces the principle that once a habeas corpus petition loses relevance, courts need not entertain further applications. It also clarifies the limits of judicial intervention in cases of alleged humiliation during proceedings.