RS & Ors. v the State of Rajasthan & Anr., 2026
The court reinforced the principle actus non facit reum nisi mens sit rea that is criminal liability attaches only to intentional acts.
Judgement Details
Court
Rajasthan High Court
Date of Decision
17 March 2026
Judges
Justice Farjand Ali
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
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The complainant’s daughter died at her matrimonial home after 10 years of marriage.
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Allegations were made that her husband and his father were pressuring her for money and involved in gambling.
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No material was found against the other family members; only the husband was originally charged.
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During trial, the trial court allowed an application under Section 319 CrPC to summon other family members.
Issues
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Whether criminal liability under Section 498-A IPC can be inferred merely from a family member’s presence in the matrimonial home?
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Whether the trial court was justified in summoning other family members without specific allegations against them?
Held
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Cognizance allowed only against the husband’s father.
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Summons set aside for all other family members.
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Criminal liability cannot be inferred solely from presence in the matrimonial home.
Analysis
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The court reinforced the principle actus non facit reum nisi mens sit rea: criminal liability attaches only to intentional acts.
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Investigative conclusions are a relevant consideration, though not binding.
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Absence of prior complaints over ten years was considered a factor in evaluating the credibility of allegations against other relatives.
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The judgment highlights judicial restraint in using Section 319 CrPC and prevents turning it into routine appellate review of police discretion.
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This decision strengthens protections for family members who are passively associated with matrimonial disputes without active involvement.