MANISH RATAN vs STATE OF M.P.

The Supreme Court analyzed the application of Sections 177 and 178 of the Code of Criminal Procedure in a case concerning jurisdiction over a complaint of dowry harassment. The Court held that the High Court erred in dismissing the appellants' revision application, as the allegations of mal-treatment were confined to Jabalpur and did not establish jurisdiction in Datia. The Court distinguished this case from Sujata Mukherjee v. Prashant Kumar Mukherjee, emphasizing that the continuing offence doctrine did not apply due to the lack of evidence of mal-treatment occurring in Datia. Consequently, the order of the High Court was set aside, affirming that the Chief Judicial Magistrate at Raipur had jurisdiction to try the case.