TJ v. State of Karnataka & Anr., 2026

The petitioner and the complainant were college classmates and friends, aged 21 and 20 years, respectively.

The petitioner sent a private Instagram Direct Message (DM) complimenting the complainant's appearance and describing her as "beautiful" using expressions commonly associated with Gen Z slang.

The complainant allegedly showed the message to her father, who was a serving IPS officer.

Based on the complaint, the police registered an FIR against the petitioner for offences relating to outraging modesty, voyeurism, stalking, and offences under the Information Technology Act.

During the investigation, the petitioner's mobile phone and laptop were allegedly seized.

The petitioner challenged the FIR before the Karnataka High Court, contending that the allegations did not constitute any criminal offence.

He further argued that the seizure of his electronic devices had not been carried out in accordance with the prescribed legal procedure.

The petitioner also submitted that he was a state-level cricketer selected to represent the Tamil Nadu Under-19 team and that continuation of criminal proceedings would irreparably damage his career.

The State opposed the petition, arguing that the petitioner had no right to make comments regarding the complainant's appearance.

The Karnataka High Court allowed the writ petition and quashed the FIR registered against the petitioner.

The Court held that the impugned Instagram chat was a private conversation between two individuals and not a public communication.

The Bench observed that although one expression used by the petitioner may have been inappropriate, it reflected contemporary "Gen Z lingo" commonly used among students.

The Court found that merely complimenting a classmate's appearance in a private message did not satisfy the statutory ingredients of stalking, voyeurism, or outraging the modesty of a woman.

It held that there was no allegation of repeated following, surveillance, invasion of privacy, or any conduct amounting to voyeurism or stalking.

The Court observed that permitting investigation on the basis of such a conversation would constitute an abuse of the process of law.

The Bench noted that continuation of the criminal proceedings would seriously jeopardize the petitioner's education and sporting career.

The Court directed the Investigating Officer to immediately return the petitioner's mobile phone and laptop, if they had indeed remained seized pursuant to the FIR.

While hearing the matter, the Court also orally remarked that procedural safeguards appeared to have been ignored because the complainant's father was a serving police officer.

The judgment reinforces the principle that criminal liability can arise only when the statutory ingredients of an offence are clearly established and not merely because a communication is perceived as inappropriate.

The Court carefully distinguished social impropriety from criminality, emphasizing that not every offensive or awkward private conversation amounts to a criminal offence.

By examining the actual contents of the Instagram chat, the Court focused on the substance of the communication rather than public perception or subjective discomfort.

The decision underscores that offences such as stalking and voyeurism require fulfillment of specific legal ingredients and cannot be invoked merely because a private compliment was unwelcome.

The Court also highlighted the importance of preventing misuse of criminal law in interpersonal disputes where the allegations do not disclose any cognizable offence.

The direction to return the petitioner's electronic devices reflects judicial concern regarding unnecessary seizure of digital devices and prolonged deprivation of personal property during investigation.

The judgment recognizes the potentially irreversible impact that unwarranted criminal proceedings may have on a young student's education, career, and reputation.

The ruling serves as an important precedent on balancing individual dignity, women's protection, freedom of private communication, and safeguards against over-criminalization in the digital age.