Latest JudgementIndian Penal Code, 1860

Beri Manoj v. State of Andhra Pradesh & Anr., 2026

The court observed that the mere presence of a lawyer in the professional capacity of giving advice or suggestions cannot amount to intimidation.

Supreme Court of India·30 January 2026

Indian Penal Code, 1860

Court

Supreme Court of India

Date of Decision

30 January 2026

Judges

Justice Aravind Kumar and Justice Prasanna B Varale

Citation

Acts / Provisions

Section 13(1)(ia), Hindu Marriage Act, 1955

Section 25, Hindu Marriage Act, 1955

Facts of the Case

The complainant, a victim in a sexual offence case, alleged that the appellant-advocate had threatened and intimidated her to give false evidence in favor of the main accused.
The prosecution’s claim was based on the Section 164 CrPC statement of the prosecutrix, where she alleged intimidation by the advocate along with the uncle and aunts of accused No.1.
The Section 161 CrPC statement of the prosecutrix recorded earlier did not mention any threat from the advocate; she only mentioned visiting his house.
The alleged threat by the advocate emerged seven days later in the Section 164 statement, showing contradictions in the complainant’s versions.
The advocate approached the Supreme Court after the High Court refused to quash the criminal intimidation case under Section 506 IPC.

Whether advice or suggestions given by a lawyer to a client in the course of professional duty can be construed as criminal intimidation?
Whether mere threats, without the intention to cause alarm, constitute an offence under Section 506 IPC?
Whether contradictions between statements under Section 161 and Section 164 CrPC can render allegations insufficient to proceed with prosecution under Section 506 IPC?
Whether vague allegations unsupported by prima facie cogent evidence can form the basis for criminal prosecution under Section 506 IPC?

Criminal intimidation case under Section 506 IPC against the advocate quashed.
Advice or suggestions by a lawyer in the course of professional duty do not amount to criminal intimidation.
Mere words without intent to cause alarm cannot constitute Section 506 IPC offence.
Vague allegations unsupported by prima facie evidence cannot sustain prosecution.

Court’s Reasoning: Focused on professional duties of lawyers, contradictions in statements, and absence of intention to cause alarm.
Legal Principles Applied that section 506 IPC requires intention to cause alarm.
Prima facie evidence is necessary to sustain prosecution; vague allegations are insufficient.
Contradictions between 161 and 164 statements undermine credibility.
Lawyers performing duties cannot be criminally intimidated for fulfilling professional obligations.
Impact on Existing Law:
- Reinforces protection for advocates in professional capacity.
- Clarifies the threshold for Section 506 IPC prosecution: mere words, absent intent, are insufficient.
- Strengthens judicial scrutiny on inconsistencies between police-recorded statements and magistrate statements.