STATE OF ORISSA vs BHARAT CHANDRA SAHU

The Supreme Court held that the High Court erred in quashing the charge under Section 494 IPC, as the offence is non-cognizable and requires a complaint by an aggrieved person as per Section 198(1) of the Code of Criminal Procedure. The Court clarified that the police could not take cognizance of the offence without a proper complaint, thus reinstating the charge under Section 494 IPC while upholding the charge under Section 498A IPC. The judgment of the High Court was set aside to the extent of the quashing of the charge under Section 494 IPC.