Source: Supreme Court 

Why in News? 

The bench of Justices Sanjay Karol and Sandeep Mehta has held that A simple verbal spat at workplace did not make the appellant liable for the offence of Intentional Insult.  

• The Supreme Court held in the case of B.V. Ram Kumar v. State of Telangana and Another (2025). 

What was the Background of the B.V. Ram Kumar v. State of Telangana and Another Case? 

• Dr. B.V. Ram Kumar (appellant) was serving as the Officiating Director at the National Institute for Empowerment of Persons with Intellectual Disabilities in Secunderabad. 
• On 2nd February 2022 he called an Assistant Professor of Pediatrics (the complainant) to his chamber through his attendant. 
• The complainant had recently recovered from COVID-19 and was experiencing ongoing medical issues at the time. 
• According to the complainant, when she entered his chamber, appellant began speaking to her in a raised voice, questioning her about filing complaints against him to higher authorities. 
• The complainant protested about his loud voice, citing her recent COVID-19 recovery and medical issues. She began experiencing physical symptoms (trembling hands and sweating) and left the chamber, saying she would submit a written reply. 
• The complainant filed a police complaint the same day, leading to an FIR being registered on 5th February 2022, at Police Station Bowenpalli, Hyderabad. 
• The initial FIR included charges under Sections 269, 270, 504, and 354 of the Indian Penal Code, 1860 (IPC).  
• During investigation, the police also found allegations that the appellant had failed to provide adequate PPE kits and gloves at the institute, potentially risking the spread of COVID-19. 
• After investigation, the police filed a chargesheet on 27th September, 2022, dropping Section 354 but maintaining charges under Sections 269, 270, and 504 of the IPC. 
• The complainant alleged that the appellant had been mentally harassing her at the workplace since October 2021, including interfering with internal complaints and sending memos during her medical leave. 
• Two witnesses from the institute (a Hindi Translator and a Data Entry Operator) provided statements saying there was no shortage of PPE kits, masks, or sanitizers at the institute. 
• The incident occurred in the context of existing complaints from students' parents about the complainant's alleged unavailability during duty hours, which were pending with Dr. Ram Kumar as Director. 
• The Trial Court (XI Additional Chief Metropolitan Magistrate, Hyderabad) took cognizance of the offences under Sections 269, 270, and 504 IPC based on the chargesheet. 
• Appellant filed a petition under Section 482 of Code of Criminal Procedure, 1973 (CrPC) in the High Court of Telangana seeking to quash the charge sheet which was dismissed by the High Court. 
• Aggrieved by the decisions of the High Court the present appeal has been filed before the Supreme Court. 

What were the Court’s Observations? 

• Supreme Court made the following Observations: 
  • The Supreme Court disagreed with the High Court and allowed the appeal. 
  • Key observations by the Supreme Court:  
    • The allegations in the chargesheet were purely conjectural. 
    • The allegations did not constitute ingredients of offences under Sections 269 and 270 IPC. 
    • The investigating officer appeared unduly influenced by the sensitive COVID-19 situation. 
    • The allegation about PPE kit shortage was refuted by witness statements. 
    • A simple verbal spat did not make the appellant liable under Section 504 IPC. 
    • As Director, it was reasonable for the appellant to have high expectations from his juniors. 
    • Reprimanding subordinates to maintain discipline cannot be treated as 'intentional insult.' 
    • Allowing criminal charges against a director for trying to maintain discipline could have disastrous consequences. 
    • The necessary ingredients constituting the offences were not present. 
• Based on the above observations the Supreme Court quashed the charge sheet filed against the appellant. 

What is Section 504 of IPC? 

• This section deals with the intentional insult with intent to provoke breach of peace. 
• This section states that whoever intentionally insults, and thereby gives provocation to any person, intending or knowing it to be likely that such provocation will cause him to break the public peace, or to commit any other offence, shall be punished with imprisonment of either description for a term which may extend to two years, or with fine, or with both. 
• It is a non-cognizable, compoundable and bailable offence and is triable by any magistrate. 
• The same section has been covered under Section 352 of Bharatiya Nyaya Sanhita, 2023 (BNS).