Showing posts with label wrongful confinement. Show all posts
Showing posts with label wrongful confinement. Show all posts

Tuesday, 20 August 2019

Whether Magistrate can order to give custody of child to mother U/S 97 of CRPC?

 Now the question arose whether in the circumstances will it speak about wrongful confinement of child on the part of the petitioner? The answer will be “No”. The person who carried the child to the hospital to fulfil the wish of her wife on 25.01.2019 and while the child was wilfully left by the respondent/wife in the custody of the petitioner because of her ill health since 2017, such a contention raised by the respondent can in no way be stated as a confinement. The learned Additional District Magistrate although initially had issued search warrant treating the same to be wrongful confinement by its order dated 28.01.2019 but in the order dated 26.02.2019 as indicated above in paragraph 2 of the order has itself held that there can be no question of “wrongful confinement by the second party” but strangely the learned court treated the matter as if dealing with the custody of the child and gave the custody of the child to the respondent/wife which is beyond the jurisdiction of Section 97 of Cr.P.C The provision of custody of child can be decided under Section 25 of the Guardian and Wards Act and the same cannot be adjudicated in the petition under Section 97 of the code. The only question which is to be decided while passing any such order by a court that there was certain wrongful confinement of a person while initiating proceeding. As has been discussed above, no matter of wrongful confinement has been made out as against the petitioner, who is the natural guardian/father of the child.
11. The Section 6 of the Hindu Minority and Guardianship Act provides that the natural guardian of any minor is the father and after him the mother.
12. As a corollary of above discussion it can be found that the impugned order dated 26.02.2019 passed by the learned trial court is wholly without jurisdiction. On the other hand, the order of the revisional court is also bad in law while the court has observed that any minor girl cannot be kept in a place against her will and will amounts to wrongful confinement. However, if the parties file a case for custody of the child, then the question of taking opinion of the child will arise as to with whom preferred to live, whether in the custody of her father or mother and that provision is not applicable in a proceeding under Section 97 of Cr.P.C
13. From what has been discussed above and in the circumstance narrated in the petition and the reply of the present petitioner before the court below it emerges that the child of the parties was kept in the custody of the petitioner by his wife voluntarily for her health problem and the same cannot be now contended as wrongful confinement and both the orders of the trial court as well as revisional court is devoid of merit and liable to be interfered. Accordingly, the orders passed by the trial court as well as revisional court is hereby quashed and set aside. It is however, observed that the parties may prefer appropriate application before the appropriate forum for custody of the child in proper manner, if so advised and till then, it is expected that the petitioner will honour the sentiment of the mother/respondent to facilitate her visit to her child as per convenience of the parties.

In the High Court of Gauhati
(Before Rumi Kumari Phukan, J.)

Sanjeev Kumar Singh  v. O. Mema Devi

Crl. Pet. 626/2019
Decided on July 16, 2019
Citation: 2019 SCC OnLine Gau 2874
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Monday, 31 August 2015

Whether parents' possession of child amount to an offence or wrongful confinement?

 A reading of the above provision would manifest that jurisdiction of the Magistrate is attracted only when he has reason to believe that any person is confined under such circumstances that the confinement amounts to an offence. Since parents' possession of the child cannot, under ordinary circumstances, amount to an offence or wrongful confinement, jurisdiction under Section 97 Cr.P.C. was not available to the Magistrate for exercising powers against the child. The Magistrate having summoned the minor has gone a step ahead to withdraw his custody from the company of his mother and then to handover to grandmother and uncle.
Equivalent Citation: 2015CriLJ3189
IN THE HIGH COURT OF CHHATTISGARH
WPC No. 2068 of 2014
Decided On: 24.03.2015

 Sonam Devi  Vs. State of Chhattisgarh

Coram:Prashant Kumar Mishra, J.


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Saturday, 27 October 2012

Allahabad HC: Magistrate can remand accused to MCR or release him on bail even though his arrest is wrongful

 The aforesaid contention of the learned counsel for the petitioner is not acceptable to us. Even conceding that the applicant was not told the reasons of his arrest as required under Section 50(1) of the Cr.P.C., his production before the Court was made with an allegation of his involvement in a substantive case. Once the applicant was produced in Court the provisions of Section 167, Cr.P.C. would apply. This section states that whenever any person is arrested and detained in custody and the investigation cannot be completed within a period of 24 hours, he is to be produced before the nearest judicial Magistrate with the relevant entries in the diary. After his arrest the applicant was produced before a Magistrate. Section 167(2), Cr.P.C. requires than when such a person has been produced before a Magistrate he may authorise the detention of the accused in such custody as such Magistrate may think fit. Under Section 437, Cr.P.C. the Magistrate was also empowered to grant him bail instead of sending him to custody. An order of the Magistrate either directing remand of the accused in custody or directing his release on bail may not be affected by any initial defect in the making of arrest. Thus the present custody of the petitioner, as being on bail under orders of the Court, may not be treated to be a wrongful detention and although suitable action may lie against the concerned police officer for non-compliance of Section 50(1), Cr.P.C., there may not be an order directing the petitioner to be set at liberty the effect of which would be to discharge him from his bail bonds

Allahabad High Court

Udaybhan Shuki vs State Of U.P. And Ors. on 18 March, 1998

Equivalent citations: 1999 CriLJ 274
Bench: S Phaujdar, M Gupta

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