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Inderjit Singh Grewal vs State Of Punjab & Anr on 23 August, 2011

In this judgment, the Hon'ble Supreme Court has taken note of the aforesaid earlier judgment in the case of Inderjit Singh Grewal Vs. State of Punjab (supra) and thereupon it is found that while considering complaints under the D.V. Act, the concept of continuing cause of action needs to be applied. In the said case, a contention regarding limitation was raised in the backdrop of prayer of the aggrieved person (wife) for return of Stridhan. The Hon'ble Supreme Court after relying upon earlier judgments, held that a continuing offence is one which is susceptible of continuance and is distinguishable from one which is committed once and for all. It was found that retention of Stridhan by the husband and his family members was a continuing offence, so long as it was covered under the expression of "economic abuse" as defined under Section 3 of the D.V. Act, ::: Uploaded on - 27/07/2021 ::: Downloaded on - 28/07/2021 06:47:28 ::: wp.372.2019 +2 13/19 pertaining definition of "Domestic Violence".
Supreme Court of India Cites 32 - Cited by 227 - B S Chauhan - Full Document

Krishna Bhatacharjee vs Sarathi Choudhury And Anr on 20 November, 2015

In the said judgment in the case of Krishna Bhattacharjee Vs. Sarathi Choudhury and another (supra), the Hon'ble Supreme Court has specifically held that the concept of continuing offence gets attracted from the date of deprivation of Stridhan and that therefore, an application in that context would have to be entertained and it cannot be thrown out on the ground of limitation. This Court is of the opinion that the definition of domestic violence under Section 3 of the D.V. Act shows that depriving an aggrieved person of not only Stridhan but also shared household, maintenance, alienation from assets, banks lockers etc, prevention from entering place of employment of the aggrieved person, would all be covered, under the concept of continuing offences. Therefore, merely because the wife in the present case was, according to her, driven out on 03.02.2011 and the complaint was filed after one year i.e. on 17.10.2012, it cannot be said that the complaint is barred by limitation. The concepts of continuing cause of actions and continuing offences would apply and the contention raised on behalf of the husband relying upon Section 468 Cr.P.C. cannot be accepted. Thus, it is ::: Uploaded on - 27/07/2021 ::: Downloaded on - 28/07/2021 06:47:28 ::: wp.372.2019 +2 17/19 found that the complaint of the wife cannot be thrown out on the ground of limitation, despite applicability of the Cr.P.C. as per Section 28 of the D.V. Act.
Supreme Court of India Cites 59 - Cited by 86 - D Misra - Full Document
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