Territorial jurisdiction in cruelty and dowry harassment complaints extends to the place where the offence continues or its consequences arise.

Territorial jurisdiction in complaints alleging continuing cruelty and dowry harassment can extend beyond the place where individual acts occurred when the offence is continuing and its consequential effect ensues elsewhere. Applying Sections 177, 178 and 179 of the Code of Criminal Procedure, 1973, the SC noted that the complaint pleaded ill-treatment at the matrimonial home, removal of the complainant to her parental home at Gaya under threat, and continued harassment. On those facts, Gaya was a where the offence continued and where its consequence ensued, so the Magistrate there had territorial jurisdiction and the proceedings were maintainable.

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Issues: Whether the criminal proceedings initiated at Gaya against the husband and his relatives were maintainable in view of territorial jurisdiction.

Analysis: The complaint alleged persistent cruelty, harassment, and dowry demands at the matrimonial home and also alleged that the complainant was taken to her parental home at Gaya under threat and as a consequence of the continuing ill-treatment. Under Chapter XIII of the Code of Criminal Procedure, 1973, Section 177 states the ordinary rule of trial at the place where the offence was committed, while Sections 178 and 179 permit inquiry or trial where an offence is committed partly in different local areas, is a continuing offence, or where the consequence of the act ensues in another local area. On the facts pleaded, the offence was not an isolated act confined to one place; it was a continuing offence spreading across more than one local area, with Gaya being the place where the consequence ensued and where the complainant was made to remain under threats.

Conclusion: The Court held that the Magistrate at Gaya had territorial jurisdiction and that the proceedings there were maintainable.

Ratio Decidendi: In complaints alleging continuing cruelty and dowry harassment, territorial jurisdiction lies not only where the acts occurred but also where the offence continues or where its consequential effect ensues, attracting clause (c) of Section 178 and Section 179 of the Code of Criminal Procedure, 1973.

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