Continuing offence and territorial jurisdiction in cruelty claims fail where no fresh acts occur at the local place.

Allegations of cruelty under Section 498A IPC were held not to constitute a continuing offence on the pleaded facts, because the alleged dowry demand, humiliation, beating and other ill-treatment occurred at Delhi. The material said to relate to Ambikapur showed only that the wife remained at her parental home, telephone calls were made, and no effort was made to bring her back; these consequences did not amount to fresh acts of cruelty there. Territorial jurisdiction therefore did not arise at Ambikapur under Sections 178 and 179 CrPC, and the proper jurisdiction lay at Delhi.

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Issues: Whether the offence alleged under Section 498A of the Indian Penal Code was a continuing offence so as to confer territorial jurisdiction on the Court at Ambikapur under Sections 178 and 179 of the Code of Criminal Procedure, 1973.

Analysis: The alleged overt acts constituting cruelty were said to have occurred at Delhi, including demand of dowry, humiliation, beating, abusive conduct, and other acts of ill-treatment. The allegations relating to Ambikapur did not disclose fresh acts of cruelty committed there; at most they indicated that the complainant-wife remained at her parental home, that telephone calls were made, and that no effort was made to bring her back. On the complaint as pleaded, the ingredients of a continuing offence were not made out, and the mere continuation of consequences at Ambikapur did not create territorial jurisdiction there.

Conclusion: The offence was not a continuing offence and the Court at Ambikapur had no jurisdiction to try it; jurisdiction lay at Delhi.

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