Facts: The petitioners, including Pravin Satyanarayan Battulwar, sought to quash proceedings initiated by the respondents, particularly Meena Pravin Battulwar, under Section 12 of the Protection of Women from Domestic Violence Act, 2005 (D.V. Act). The petitioners argued that there was no relationship in the nature of marriage between Pravin and Meena, and they never lived in a shared household. Meena had filed an FIR alleging sexual abuse by Pravin, and a charge sheet was filed. Pravin later married Chayarani, another petitioner. Meena claimed that she had conceived twice with Pravin, resulting in one aborted pregnancy and the birth of a child.
Procedural Posture: The petitioners filed a criminal writ petition in the High Court of Judicature at Bombay, Nagpur Bench, seeking to quash the proceedings and impugned orders issued under the D.V. Act by the Judicial Magistrate First Class, Chamorshi.
Issue: Whether the relationship between Pravin and Meena constitutes a "relationship in the nature of marriage" as defined under the D.V. Act, and whether the proceedings under Section 12 of the D.V. Act should be quashed. Additionally, whether the complaint against Petitioners 2 to 4 should be quashed due to the absence of specific allegations against them.
Holding: The High Court partly allowed the petition. The Court refused to quash the complaint against Petitioner No. 1 (Pravin). However, the complaint against Petitioner Nos. 2 to 4 was quashed.
Reasoning: The Court considered the guidelines laid down by the Supreme Court in D. Velusamy Vs. D. Patchaiammal, 2010 DGLS(SC) 835 and Indra Sarma Vs. V.K. Sarma, (2013) 15 SCC 755 to interpret the 'relationship in the nature of marriage'. The Court noted that the complaint alleged that Pravin and Meena lived as husband and wife, had a sexual relationship, and that Pravin acknowledged the relationship. The Court also considered the fact that a child was born out of the relationship. The Court opined that evidence was required to be led by the parties to make an informed decision in the interest of justice. The Court found no specific allegations against Petitioners 2 to 4 in the complaint to invoke the provisions of the D.V. Act, thus quashing the complaint against them.