Smt Kusuma S v. the State of Karnataka

Karnataka HC20 Jul 2026WP/21861/2026

Case brief

AI extract

What is this about?

Registration of FIR; mandatory action on complaint alleging cognizable offences; Lalita Kumari vs. Government of Uttar Pradesh (2014) 2 SCC 1; writ of mandamus; police protection; matrimonial home; Articles 226 and 227 Constitution of India; GM-POLICE; WP No. 21861 of 2026; Chennammanakere Acchakattu Police Station Bengaluru; Commissioner of Police Bengaluru City; seven-day compliance timeline; Karnataka High Court; Suraj Govindaraj J.

What did the court decide?

Writ petition allowed; mandamus issued directing respondent No.1 to act on the petitioner's complaint dated 02.07.2026 (Annexure-G) in terms of Lalita Kumari vs. Government of Uttar Pradesh within seven days from receipt of copy of the order; respondent No.2 directed to examine and pass necessary orders on any protection required to the petitioner during the course of enquiry.

Smt Kusuma S Vs the State of Karnataka — Writ and Judicial Review | Karnataka HC (2026)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether respondent No.1 was bound to act on the petitioner's complaint dated 02.07.2026 (Annexure-G) by registering an FIR, the allegations therein pertaining to cognizable offences. +1 more

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Court's answer

On perusal of Annexure-G, the complaint discloses several allegations of cognizable offences.

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Ratio / Principle

Since the complaint alleges cognizable offences, the respondents were required to take necessary action in terms of the Hon'ble Supreme Court's decision in Lalita Kumari vs. Government of Uttar Pradesh (i.e., registration of FIR); their failure to do so led to the petition.

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Key takeaways

A mandamus is issued directing respondent No.1 to act on the petitioner's complaint dated 02.07.2026 at Annexure-G in terms of the decision in Lalita Kumari vs. Government of Uttar Pradesh.ratio¶¶40
Compliance with the mandamus is directed within a period of seven days from the date of receipt of copy of the order.ratio¶¶46
If during the course of enquiry it is found that any protection is required to be made available to the petitioner, respondent No.2 is directed to look into the issue and pass necessary orders.

Detailed headnote1 paragraphs

High Court of Karnataka (Suraj Govindaraj J), WP No. 21861 of 2026 (GM-POLICE), decided 20 July 2026: The petitioner's complaint dated 02.07.2026 (Annexure-G) to the Chennammanakere Acchakattu Police Station, Bengaluru, alleging cognizable offences, was not acted upon by registration of an FIR, nor did her representation dated 07.07.2026 (Annexure-J) to the Commissioner of Police produce action. Holding that where a complaint discloses allegations of cognizable offences, the police were required to take necessary action in terms of the Hon'ble Apex Court's decision in Lalita Kumari vs. Government of Uttar Pradesh, (2014) 2 SCC 1, the Court allowed the writ petition filed under Articles 226 and 227 of the Constitution of India, issued a mandamus directing respondent No.1 to act on the complaint within seven days from receipt of copy of the order, and further directed respondent No.2 to look into and pass necessary orders on any protection found required to be made available to the petitioner during the course of enquiry.

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HC-KAR NC: 2026:KHC:37100 WP No. 21861 of 2026

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CNR: KAHC010477852026

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IN THE HIGH COURT OF KARNATAKA AT BENGALURU

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DATED THIS THE 20^TH DAY OF JULY, 2026

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BEFORE

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THE HON'BLE MR. JUSTICE SURAJ GOVINDARAJ WRIT PETITION NO. 21861 OF 2026 (GM-POLICE)

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BETWEEN:

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SMT. KUSUMA S. AGED ABOUT 30 YEARS W/O C.VINAY KUMAR D/O SHIVAPPA R. R/AT NO.7/3, BALAJINAGARA VIVEKANANDANAGARA KATRIGUPPE, BSK 3^RD STAGE BANGALORE - 560085.

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…PETITIONER

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(BY SRI SHANKARAPPA., ADVOCATE)

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AND:

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Digitally signed by SHWETHA RAGHAVENDRA Location: HIGH COURT OF KARNATAKA

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THE STATE OF KARNATAKA REPRESENTED BY CHENNAMMANAKERE ACCHAKATTU POLICE STATION BENGALURU.

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THE COMMISSIONER OF POLICE BENGALURU CITY POLICE NO. 1, INFANTRY ROAD BENGALURU 560001.

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…RESPONDENTS (BY SMT. SARITHA KULKARNI, AGA FOR R1 & R2)

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF MANDAMUS DIRECTING THE 1^ST RESPONDENT TO REGISTER THE COMPLAINT OF THE PETITIONER DATED 02/07/2026 AT ANNEXUREG AND ISSUE FIR TO THE PETITIONER WITH PROTECTION.

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HC-KAR

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NC: 2026:KHC:37100 WP No. 21861 of 2026

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CNR: KAHC010477852026

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THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

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CORAM: HON'BLE MR. JUSTICE SURAJ GOVINDARAJ

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ORAL ORDER

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Learned AGA accepts notice for respondents No.1 and 2.

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The Petitioner is before this Court seeking the following reliefs:

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a. Issue a Writ of Mandamus directing the 1^st Respondent to register the complaint of the Petitioner dated 02/07/2026 at ANNEXURE-G and issue FIR to the Petitioner with protection.

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b. Issue a Writ of Mandamus directing the 2^nd Respondent to consider the representation dated 07/07/2026 at ANNEXURE-J by directing the 1^st Respondent to register the complaint of the Petitioner and provide protection to the Petitioner.

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c. Issue a Writ of Mandamus directing Respondent No.1 and Respondent No.2 to extend round-the-clock or necessary police protection to the Petitioner to safeguard her life, limb, modesty, and to ensure her unhindered, safe residence within her matrimonial home;

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d. Pass such other orders or reliefs as this Hon'ble Court deems fit under the facts and circumstances of the case, to meet the ends of justice.

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HC-KAR

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NC: 2026:KHC:37100 WP No. 21861 of 2026

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CNR: KAHC010477852026

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The grievance of the petitioner is that the complaint which had been submitted by the petitioner on 02.07.2026 at Annexure-G to respondent No.1 has not been acted upon by registering an FIR.

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A perusal of Annexure-G indicates that the allegations which have been made are as regards cognizable offences. When that is so, it was but required for the respondents to have taken necessary action in terms of the decision of the Hon'ble Apex Court in Lalita Kumari vs. Government of Uttar Pradesh¹ . The same not having been done, the petitioner is before this Court seeking for the aforesaid relief.

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Having perused Annexure-G, it is seen that there are several allegations made as regards cognizable offences. As such, this Court passes the following;

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ORDER

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i. The writ petition is allowed.

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ii. A mandamus is issued, directing respondent No.1 to act on the complaint of the petitioner dated 02.07.2026 at Annexure-G in terms of the decision of the Hon'ble Apex Court in Lalita Kumari vs. Government of Uttar Pradesh

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1 (2014) 2 SCC 1

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HC-KAR

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NC: 2026:KHC:37100 WP No. 21861 of 2026

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CNR: KAHC010477852026

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within a period of seven days from the date of receipt of copy of this order.

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iii. If during the course of enquiry, it is found that any protection is required to be made available to the petitioner, respondent No.2 is directed to look into the issue and pass necessary orders.

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SD/(SURAJ GOVINDARAJ) JUDGE

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List No.: 1 Sl No.: 40

Smt Kusuma S v. the State of Karnataka

Case brief

What is this about?

What did the court decide?

Smt Kusuma S v. the State of Karnataka

Case brief

What is this about?

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What the court decided

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