S. 506 IPC| Mere Threats Without Intent To Cause Alarm Not Criminal Intimidation: Delhi High Court
The Court dismissed a plea challenging a trial court’s decision to discharge four accused persons in a rape case filed by the complainant.

The Delhi High Court has ruled that mere threats by an accused, without the intention to cause alarm to the complainant, do not constitute the offence of criminal intimidation under the Indian Penal Code.
The Single Bench of Justice Amit Mahajan observed, “A bare perusal of Section 506 of the IPC makes it clear that before an offence of criminal intimidation is made out, it must be established that an accused had an intention to cause alarm to the complainant. Mere threats given by the accused not with an intention to cause alarm to the complainant would not constitute an offence of criminal intimidation."
Advocate Sunita Arora appeared for the Petitioner, and APP Naresh Chahar appeared for the Respondent.
Facts of the Case
The Court dismissed a plea challenging a trial court’s decision to discharge four accused persons in a rape case filed by the complainant. The FIR, registered in 2019 under Sections 376 (rape) and 506 (criminal intimidation) of the Indian Penal Code, alleged that the primary accused had physically exploited the complainant for 13-14 years under false promises of marriage. Additionally, the complainant accused the primary accused’s brother and mother of threatening her instead of restraining him.
The Trial Court had previously discharged the accused, citing insufficient evidence collected by the prosecution to establish a prima facie case against them. Upholding this decision, the High Court found that the impugned order was aligned with established legal principles and required affirmation.
Court's Observations
The Court observed that the Investigating Officer (IO) failed to collect documentary or medical evidence to corroborate the complainant’s claim that her father was hospitalized due to alleged threats.
“The learned ASJ's observations regarding the petitioner's allegations against Respondent Nos. 2 to 5 are well-founded. The evidence on record does not substantiate the claims of facilitation, conspiracy, or criminal intimidation,” the Court stated.
The Single Judge concluded that the complainant's allegations were plagued with infirmities and failed to raise grave suspicion against the accused persons. He further stated that the material on record did not indicate the commission of the alleged offence.
“As discussed above, the learned Trial Court has evidently applied its judicial mind and considered the totality of the facts before discharging Respondent Nos. 2 – 5 of the alleged offences in light of the absence of grave suspicion against them. Considering the aforementioned facts, no ground is made out to warrant any interference in the impugned order,” the Court held.
Cause Title: X v. State & Ors. [Neutral Citation No. 2025: DHC: 441]
Appearance:-
Petitioner: Advocate Sunita Arora
Respondent: APP Naresh Chahar, Advocates Chirag Jamwal, Ajit Amar, Akashdeep Kakka
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