High Court exercises inherent jurisdiction under Section 482 Cr.P.C. to prevent abuse of legal process, ruling in favor of Dr. Renu Rana.
In a significant ruling, the Patna High Court has quashed criminal proceedings against Dr. Renu Rana, a medical practitioner, who was previously accused of providing incorrect medical advice leading to allegations of cheating and criminal breach of trust. The judgment, delivered by Justice Sunil Dutta Mishra on July 24, 2026, underscores the court's power under Section 482 of the Code of Criminal Procedure, 1973, to intervene in cases where legal proceedings are deemed an abuse of the court process.
The case originated from a complaint by an advocate, who accused Dr. Rana of advising a medical termination of pregnancy based on an ultrasound report, allegedly resulting in the advocate's health deterioration after consuming prescribed medicines. The advocate further claimed that Dr. Rana refused to return the consultation fees. However, the complainant eventually delivered a healthy child, prompting accusations of false medical advice.
The learned Magistrate initially took cognizance of the complaint, leading to criminal revision proceedings. Upon review, the Revisional Court upheld the charges, prompting Dr. Rana to seek relief from the High Court.
The High Court's decision focused on whether the allegations indeed constituted an offense under Sections 406 and 420 of the Indian Penal Code. Justice Mishra observed that the complaint lacked essential elements of cheating and criminal breach of trust, as there was no evidence of fraudulent intention or entrustment of property by Dr. Rana. The court emphasized that the continuation of such proceedings would amount to an abuse of legal process.
Citing precedents from the Supreme Court, the judgment reaffirmed that mere errors in medical judgment do not constitute criminal offenses. The court also noted the absence of any substantial evidence supporting the allegations against Dr. Rana, including any independent medical opinion questioning her professional judgment.
This ruling reinforces the judicial principle that inherent court powers should be exercised sparingly and only in cases where legal processes are clearly abused. The decision provides relief to medical professionals, emphasizing the need for clear evidence of criminal intent before pursuing legal action in cases involving professional judgment.
Bottom line:-
The inherent jurisdiction under Section 482 of the Cr.P.C. can be exercised to quash criminal proceedings where allegations fail to disclose the essential ingredients of the offences or continuation of proceedings amounts to abuse of the process of law.
Statutory provision(s):
Section 482 of the Code of Criminal Procedure, 1973, Sections 406 and 420 of the Indian Penal Code, 1860.
Dr. Renu Rana v. The State of Bihar, (Patna) : Law Finder Doc id # 2947840
