Skip to content
Order
  • Library
  • Features
  • About
  • Blog
  • Contact
Get started
Book a Demo

Order

At Order.law, we’re building India’s leading AI-powered legal research platform.Designed for solo lawyers, law firms, and corporate legal teams, Order helps you find relevant case law, analyze judgments, and draft with confidence faster and smarter.

Product

  • Features
  • Blog

Company

  • About
  • Contact

Legal

  • Privacy
  • Terms

Library

  • Acts
  • Judgments
© 2025 Order. All rights reserved.
  1. Home/
  2. Library/
  3. High Court Of Meghalaya/
  4. 2024/
  5. January

Sane Concieta B. Sangma vs. State of Meghalaya and 4 Ors.

Decided on 31 January 2024• Citation: Crl.Petn./73/2023• High Court of Meghalaya
Download PDF

Read Judgment


               Serial No. 01                                                      
               Supplementary List                                                 
                               HIGH  COURT  OF MEGHALAYA                          
                                    AT SHILLONG                                   
              Crl. Petn. No. 73 of 2023                                           
                                                   Date of Order: 31.01.2024      
              Smti Sane Concieta B. Sangma Vs.   State of Meghalaya & 4 Ors.      
              Coram:                                                              
                                    B. Bhattacharjee, Judge                       
                        Hon’ble Mr.                                               
              Appearance:                                                         
              For the Petitioner/Appellant(s) : Mr. V.G.K. Kynta, Sr. Adv. with   
                                            Mr. H. Wanshong, Adv.                 
              For the Respondent(s)    :    Mr. K.P. Bhattacharjee, GA, (R.1-4)   
              i)   Whether approved for reporting in       Yes/No                 
                    Law journals etc.:                                            
              ii)  Whether approved for publication                               
                   in press:                               Yes/No                 
                              J U D G M E N T & O R D E R                         
                   This criminal petition under Section 401 r/w Section 482 of the
              Criminal Procedure Code, 1973 has been filed by the petitioner for setting
              aside and quashing of the order dated 14.01.2022 and order dated    
              23.05.2023 passed by the Judicial Magistrate First Class, West Garo Hills
              District, Tura in GR No. 59 of 2021 arising out of the Tura Women PS
              Case No. 17(04)2019 under Section 323 IPC r/w Section 75/82 of the  
                                           1                                      

              Juvenile Justice (Care and Protection of Children) Act, 2015 and also the
              order dated 23.06.2022 passed by the District and Sessions Judge, Tura in
              Crl. Rev. No. 02/2022. The petitioner also prayed for quashing of the
              entire proceeding of the GR No. 59 of 2021.                         
              1.      The brief fact of the case is that the petitioner is a co-founder of
              Aeroville Higher Secondary School, Tura and is holding the post of  
              Headmistress in the said school since the year 1995. In addition to 
              teaching Economics in class X, the petitioner also teaches Grammar to
              the students of class I and II of the school. The petitioner is well known
              and respected in the society especially by virtue of being a good   
              educationist and even the State government recognizes the services of the
              petitioner as a pioneer in the field of education. On 25.04.2019, a written
              complaint was filed before the Officer In-charge, Tura Women Police 
              Station, West Garo Hills against the petitioner by the respondent No.5
              alleging that her daughter aged about 7(seven) years studying in class II
              of Aeroville Higher Secondary School, Tura, was physically abused by
              the petitioner on 24.04.2019 in the school premises. On the basis of the
              written complaint, the Tura Women PS Case No. 17(04)2019 under      
              Section 323 IPC r/w Section 75/82 of the Juvenile Justice (Care and 
              Protection of Children) Act, 2015 (in short JJ Act) was registered and
              investigated into. On the completion of the investigation, a charge sheet
              under the aforesaid section of law was filed on 28.10.2020 and the  
              learned trial court took cognizance of the matter on 14.01.2022. At the
              trial, a prayer for discharge was made on behalf of the petitioner but the
              learned trial court after hearing the parties, by impugned order dated
                                           2                                      

              14.01.2022 declined to entertain the prayer of the petitioner and ordered
              for framing of charges. The said order was challenged by the petitioner
              before the court of the Sessions Judge, Tura, in Crl. Rev. No. 02/2022 and
              the learned Sessions Judge by the impugned order dated 23.06.2022 held
              that Section 82 of the JJ Act is not attracted in the matter and modified
              the order dated 14.01.2022 to that extent. Inspite of passing of the order
              dated 23.06.2022 by the Sessions Judge, Tura, the learned trial court vide
              impugned order dated 23.05.2023 again directed for framing of charges
              against the petitioner under Section 323 IPC and Section 75 and 82(1) of
              the JJ Act. Being aggrieved, the petitioner preferred this criminal petition
              before this Court challenging all the aforementioned impugned orders and
              also for quashing and setting aside of the entire proceeding of the GR
              Case No. 59/2021 pending before the trial court.                    
              2.      Mr. V.G.K. Kynta, learned Sr. counsel appearing for the     
              petitioner submits that in terms of Section 1(4) of the JJ Act, the 
              provisions of that Act shall apply only to the matters concerning   
              “Children in need of Care and Protection” and “Children in Conflict with
                                                                    Care          
              Law” and going by the defination of the terms “Children in need of  
              and Protection” and “Children in Conflict with Law” as provided in  
              Section 2(13) and 2(14) of the JJ Act, the child in question in the present
              case would not come under the purview of the said Act. The learned Sr.
              counsel contends that none of the aforesaid provisions of the JJ Act, even
              in their widest possible interpretation, can include the child in question in
              the present case within the periphery of the ambit of Section 75 of the Act
              and consequently, no trial for any offence can proceed against the  
                                           3                                      

              petitioner in the instant case. It is also the submission of the learned Sr.
              counsel that taking of cognizance of an offence under Section 323 IPC
              vide order dated 14.01.2022 by the trial court on the basis of the charge
              sheet dated 28.10.2020 is clearly barred under Section 468 Cr.PC and the
              trial thus vitiated being illegal and without jurisdiction. It is also
              contended that no further proceeding under Section 323 IPC r/w Section
              75 JJ Act, can continue as the period for taking cognizance of an offence
              under Section 323 IPC has lapsed at the end of one year of the      
              registration of the FIR dated 25.04.2019.                           
              3.      The learned Sr. counsel for the petitioner next refers to Section
              88 and 89 IPC and submits that where a teacher in course of imparting
              education subjects a child to corporal punishment bonafide with the aim
              to discipline the child, it is implied that the teacher is given consent by
              the parent to enforce discipline for the welfare of the child and in such a
              case, a teacher cannot be said to have committed any offence punishable
              under law. He submits that in addition to the special exemptions carved
              out by the said provisions of Section 88 and 89 IPC, a teacher is also
              protected from criminal action by application of common law principle of
               loco parentis                                                      
              “          ”. To buttress his argument, the learned Sr. counsel places
              reliance on a judgment dated 18.02.2020 of the High Court of Kerela 
              rendered in Crl. MC. No. 5388 of 2019 (C), Mathew E.T vs. State of  
              Kerela & Ors. and submits that the Legislature has not made the act of
              corporal punishment punishable where it is inflicted by a teacher. Relying
              on the propositions laid down in the aforesaid judgment, he submits that
              when the Legislature has exempted a teacher from the purview of Section
                                           4                                      

              82 of the JJ Act, such teacher cannot be otherwise roped in within the
              contours of Section 75 of the Act. The learned Sr. counsel submits that
              the legal infirmities and basic jurisdictional issues in the instant matter
              are prima facie borne out of the record of the case and not result of any
              factual dispute being raised on behalf of the petitioner. He contends that
              further continuation of the trial against the petitioner would result in
              abuse of process of law and prays for setting aside and quashing of all the
              impugned orders and also the entire proceedings of the case.        
              4.      On the other hand, Mr. K.P. Bhattacharjee, learned GA submits
              that in view of Section 17(1) of the Right of Children to Free and  
              Compulsory Education Act, 2009, no child should be treated with any 
              corporal punishment. He places on record a copy of the notification No.
                                          st                                      
              EDN/RTE.222/2011/40  dated 31  October 2011  issued by the          
              Government of Meghalaya and submits that it is specifically provided
              therein that no child shall be subjected to any physical punishment and
              mental harassment in any school. He further refers to Section 2(12) of the
              JJ Act and submits that any person who has not completed the age of 18
                                    and would definitely come under the purview   
              years is regarded as “child”                                        
              of the JJ Act. He contends that the FIR and the charge sheet in the instant
              matter prima facie disclose about the role of the petitioner in treating the
              victim child with physical abuse and whether the action of the petitioner
              was in good faith or not is a subject matter of evidence which can only be
              revealed at the stage of the trial of the case. The learned GA places
              reliance on a decision of the High Court of Delhi reported in 2001 (57)
              DRJ  456(DB), Parents Forum for Meaningful Education & Anr. vs.     
                                           5                                      

              Union of India and Anr. and contends that children cannot be subjected to
              corporal punishment and the State cannot be a silent spectator of violation
              of any of the norms of child welfare. He also submits that there is no
              merit in the present criminal petition and prays for dismissal of the same.
              5.      The  respondent No.5, the complainant, has not entered      
              appearance before this Court inspite of service of due notice upon her.
              6.      From the contentions raised on behalf of the petitioner, it is
              apparent that the petitioner’s case is based upon the notion that by virtue
              of provisions contained in Section 1(4), 2(13) and 2(14) of the JJ Act, the
              victim child in question will not come under the purview of the JJ Act
              and for the same reason, the petitioner cannot be charged under Section
              75 of the said Act. The law in this point stands clarified by the judgment
              of the Apex Court reported in (2017) 7 SCC 578, Exploitation of     
              Children in Orphanages in State of Tamil Nadu, In Re. Vs. Union of India
              and Ors. Paragraph 64 of the said judgment lays down: -             
                   “64. Even though a child in need of care and protection is defined
                   in Section 2(14) of the Juvenile Justice (Care and Protection of
                   Child                                                          
                        ren) Act, 2015 (hereinafter referred to as “the JJ Act”) the
                   definition does not specifically include some categories of children.
                   Consequently, we are of the view that since the JJ Act is intended
                   for the benefit of children and is intended to protect and foster
                   their rights, the definition of a child in need of care and protection
                   must be given a broad interpretation. It would be unfortunate if
                   certain categories of children are left out of the definition, even
                   though they need as much care and protection as categories of  
                   children specifically enlisted in the definition. Beneficial   
                   legislations of the kind that we are dealing with demand an    
                   expansive view to be taken by the Courts and all concerned.    
                                                                  ”               
                                           6                                      

              7.      Read in the above light, there remains no iota of doubt that the
              Legislature has never intended to exclude any category of child from the
              purview of the JJ Act. The d         child in need of care and      
                                      efination of a “                            
              protection                                                          
                      ” given in Section 2(14) of the JJ Act should be given a broad
              and purposeful interpretation, it ought not to be treated as exhaustive but
              illustrative and furthering the requirement of social justice. It is well
              settled that a provision of a statute be interpreted to meet the purpose and
              purport it needs to serve and therefore, it is clear that any person who has
              not completed eighteen years of age would come under the purview of the
              JJ Act. The petitioner, as such, cannot claim any immunity from being
              prosecuted under the law in the event of contravention of provision of
              Section 75 of the JJ Act.                                           
              8.      In so far as the contention of the petitioner basing on Section 88
              and 89 IPC is concerned, it appears to be recognized that a person in the
              position of a teacher shall for the purpose of enforcing discipline and
              correction has some authority to impose corporal punishment with    
              impunity provided the corporal punishment inflicted is moderate and 
              reasonable. But when the teacher covered by Section 88 IPC exceeds the
              authority and inflicts such harm as is unreasonable and immoderate, he
              has no protection under law. Section 89 IPC opens with the word,    
               nothing which is done with good faith for the benefit of the person
              “                                                    ”. So,         
              condition precedent for invocation of Section 89 IPC is that the act
              complained of must be for the benefit of the child. The applicability of
              Section 88 and 89 IPC and administering of corporal punishment of   
              students by teachers came up for consideration in M. Natesan Vs. State of
                                           7                                      

              Madras reported in AIR 1962 Madras 216 wherein it was held by       
              Madras High Court that: -                                           
                       cannot be denied that having regard to the peculiar position of a
                   “ It                                                           
                   school teacher he must in the nature of things have authority to enforce
                   discipline and correct a pupil put in his charge. To deny that authority
                   would amount to a denial of all that is desirable and necessary for the
                   welfare, discipline and education of the pupil concerned. It can
                   therefore, be assumed that when a parent entrusts a child to a teacher,
                   he on his behalf impliedly consents for the teacher to exercise over the
                   pupil such authority. Of course, the person of the pupil is certainly
                   protected by the penal provisions of the Penal Code, 1860. But the same
                   Code has recognised exceptions in the form of ss. 88 and 89. Where a
                   teacher exceeds the authority and inflicts such harm to the pupil as may
                   be considered to be unreasonable and immoderate, he would naturally
                   lose the benefit of the exceptions. Whether he is entitled to the benefit of
                   the exceptions or not in a given case will depend upon the particular
                   nature, extent and severity of                                 
                                         the punishment inflicted.”               
              9.      What transpires from the above view is that it is the severity of
              punishment or injury which makes the distinction between corporal   
              punishment and cruelty to a child. Since the case of the petitioner is not
              based on any factual assertion or dispute, it cannot be said at this stage
              that the act complained of falls under which category of offence. Whether
              the petitioner is entitled to the benefit of the exceptions as provided by
              Section 88 and 89 IPC will depend upon the particular nature, extent and
              severity of the punishment inflicted to the victim child in the present case
                                           8                                      

              and hence a subject matter of evidence. Resultantly, reference to the
              provision of Section 88 and 89 IPC at this stage is of no help to the
              petitioner.                                                         
              10.     The proposition of law laid down in the case of Mathew E.T  
              (supra) relied on by the petitioner is based on the facts and circumstances
              of that case. In the said case, the Madras High Court took into     
              consideration the allegations made in the FIR and on a scrutiny of the
              same, came to a finding that the allegation in the FIR cannot be said to
              one involving intentional use of force in order to commit an offence to
              cause injury and such an act should predominantly be seen as an act on
              the part of the teacher to correct the pupil, which inherent power has been
              conferred by general law on the teacher by the well-known common law
                         loco parentis                  such an act of the        
              principle of “        ”. It was also held that                      
              petitioner/accused would not constitute an offence as envisaged in  
              Section 75 of the JJ Act. The action complained of in the said case was
                            corporal punishment                                   
              considered to be “             ” as per Section 2(24) of the JJ Act 
              and as the said action stood excluded by the Parliament from the purview
              of Section 82, it was held that the petitioner/accused cannot be otherwise
              roped in within the contours of Section 75 of the JJ Act. However, in the
              said judgment, it was also observed that if the so-called penal measure
              taken by a teacher grossly exceeds the permissible proportion of a penal
              measure that can be taken by a teacher for disciplining the pupil and the
              act otherwise discloses serious offence, then of course, it might stand in a
              different footing and being matters of question of facts, will have to be
              assessed in the matrix of the facts and circumstances of each case. 
                                           9                                      

              11.     Further, a bare reading of provisions of Section 17(1) of the
              Right of Children to Free and Compulsory Education Act, 2009 and    
              Section 82 of the JJ Act make it clear that the present days, corporal
              punishment is not recognized by law. The notion that a child has to be
              physically punished to maintain discipline stands replaced by the   
              operation of basic human rights of a child and instead of corporal  
              punishment, correctional methods are recognized in law. However,    
              parents, teachers and other persons in loco parentis are entitled as a
                                              “          ”                        
              disciplinary measure to apply a reasonable degree of force to their 
              children or pupils old enough to understand its purpose, but if the 
              punishment is given out of spite or for some other non-disciplinary reason
              or if the degree of force is unreasonable, it is unlawful. The above
              understanding would also be in consonance with the National Charter for
              Children, 2003 adopted by the Govt. of India vide Resolution No. 6- 
                               th                                                 
              15/98-C.W., dated 9 February, 2004, issued by Ministry of Human     
              Resource Development. The clauses 9(a) and 9(b) thereof stipulate as
              follows: -                                                          
                    9. (a) All children have a right to be protected against neglect,
                   “                                                              
                   maltreatment, injury, trafficking, sexual and physical abuse of all
                   kinds, corporal punishment, torture, exploitation, violence and
                   degrading treatment.                                           
                   (b) The State shall take legal action against those committing such
                   violations against children even if they be legal guardians of such
                   children                                                       
                          .”                                                      
                      Thus, it is crystal clear that a teacher or a parent or even a
                                          10                                      

              guardian or any other person in loco parentis has no absolute protection
                                       “          ”                               
              from criminal action by application of common law principle of loco 
                                                                   “              
              parentis . Though the Indian Penal Code (IPC) has recognized some   
                     ”                                                            
              exceptions in the form of Section 88 and 89 of the Code, the same would
              not apply in case where the injury inflicted causes harm to the pupil as
              may  be considered to be unreasonable and immoderate. Since in the  
              present case the petitioner has not based her case on any factual assertion
              or dispute, the severity of the allegations made against her can only be
              determined at the trial.                                            
              12.     Coming next to the plea of limitation raised by the petitioner on
              the basis of Section 468 Cr.PC, it is seen that the petitioner has been put
              to face the trial under Section 323 IPC and also for an offence under
              Section 75 of the JJ Act. Section 468 (3) Cr.PC provides that the period
              of limitation, in relation to offences which may be tried together, shall be
              determined with reference to the offence which is punishable with more
              severe punishment. The punishment prescribed in Section 75 JJ Act is
              imprisonment for a term which may extend to three years or with fine of
              one lakh rupees or with both. The period of limitation prescribed for such
              an offence is three years as per Section 468(2)(c) Cr.PC. In the present
              case, the FIR was filed on 25.04.2019 and the trial court took cognizance
              of the matter on 14.01.2022, well within the period of three years  
              prescribed by Section 468(2)(c) Cr.PC. In such a situation, by applying
              the mandate of law contained in Section 468 (3) Cr.PC, it cannot be said
              that the taking of cognizance of the matter by the trial court was barred by
              law and hence, the plea of limitation raised by the petitioner has no merit.
                                          11                                      

              13.     For what has been discussed above, the petitioner has failed to
              make  out a case for interference with the impugned order dated     
              23.06.2022 passed by the Sessions Judge, Tura in Crl. Rev. No. 02/2022.
              Consequently, the prayer for quashing and setting aside of the entire
              proceeding of GR No. 59 of 2021 arising out of Tura Women PS Case   
              No.  17(04)2019 also stands rejected. The impugned order dated      
              14.01.2022 of the trial court of the Judicial Magistrate First Class, Tura,
              merges with the order dated 23.06.2022 of the Sessions Judge and hence,
              needs no interference by this Court. However, the impugned order dated
              23.05.2023 passed by the learned trial court stands interfered to the extent
              it directs for framing of charges against the petitioner under Section 82(1)
              of the JJ Act in contradiction of the order dated 23.06.2022 of the 
              Sessions Judge. The learned trial court of Judicial Magistrate First Class,
              West Garo Hills, Tura, shall now proceed to frame charges against the
              petitioner in terms of the order dated 23.06.2022 of the Sessions Judge
              and shall complete the trial expeditiously without any further delay in
              accordance with law.                                                
              14.     With the aforesaid direction this criminal petition stands  
              disposed of.                                                        
                                                               Judge              
              Meghalaya                                                           
              31.01.2024                                                          
              “N. Swer, Stenographer Gr II. ”                                     
                                          12