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DAMODARAM SANJIVAYYA NATIONAL LAWUNIVERSITY

VISAKHAPATNAM

SUBJECT
CRIMINAL INTIMIDATION, INSULT AND ANNOYANCE

FACULTY
Prof. (Dr.) Bhavani Prasad Panda

Prof. Vijaya Lakshmi

PROJECT TITLE
Indian Penal Code- II

NAME OF THE STUDENT: R.Sowmya


SEMESTER: IV
ROLL NO: 2018LLB119

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ACKNOWLEDGEMENT

It is deemed appropriate to thank everyone who facilitated in the completion of this case study.

Firstly, we would like to thank Prof. Dr. S. Surya Prakash, Vice Chancellor of Damodaram
Sanjivayya National Law University for providing us this opportunity to research in this field
of law and providing the pre-requisite infrastructure necessary for such an endeavour.

I would also like to provide our deepest gratitude to our Professors, Prof. Dr. Bhavani Prasad
Panda and Prof. Vijaya Lakshmi, Damodaram Sanjivayya National Law University for their
continuous support and guidance which was essential to the completion of this project even
during the lockdown.

And lastly I would like thank my friends and parents who assisted me in completing this paper.

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INDIAN PENAL CODE-II

SYNOPSIS

Criminal Intimidation, Insult and Annoyance

Tittle of the research project: Chapter XXII of the Indian Penal Code,1860--- “Criminal
Intimidation, Insult and Annoyance”.

Introduction:

Chapter XXII of Indian Penal Code, 1860 deals with Criminal Intimidation, Insult and
Annoyance. It comprises of eight sections from Section 503 to section 510. These are offences
which does not affect physically but are still punishable. Section 503 IPC deals with Criminal
Intimidation. Section 504 deals with Intentional Insult with intent to provoke breach of the
peace. Section 505 IPC deals with Statements conducting to Public Mischief. The Punishment
for criminal intimidation is dealt under Section 506 IPC. Section 507 IPC deals with Criminal
Intimidation by an anonymous communication. An act caused by inducing person to believe
that he will be rendered an object of the Divine displeasure is dealt under Section 508 IPC.
Section 509 IPC deals with Word, gesture or act intended to insult the modesty of a woman.
Misconduct in public by a drunken person is dealt under Section 510 IPC.

Research Questions:

1. Whether any word, gesture or act intended to insult the modesty of a woman is an
offence or not?
2. Whether an act is punishable even though it does not physically affect a person?
3. Whether any statement made by a person to create or promote enmity or hatred between
classes is an offence?

Literature Review:

1. Prof N V Paranjape: The Indian Penal Code 1st Edition


This book is preferred by the researcher because this book has a good number of
comments and illustrations regarding the section of IPC which makes the researcher to
understand the said section very clearly.

2. K. D Gaur, Indian Penal Code:This book is preferred by the researcher because this book
has good number of practical illustrations under the sections. This book has various comments
and explanations under each section of IPC.

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Research Methodology:

Nature of the study: Analytical and critical and descriptive study

Sources of study:

Primary sources- Indian Penal Code, 1860 Bare Act and Judgements of High Courts and
Supreme Court of India.

Secondary sources: R & D Indian Penal code and the K.D Gaur Indian Penal Code.

Mode of citation: Blue book 19th edition.

Scope of the study: The study of researcher is limited to the extent of the Indian penal code
and it is confined to only chapter XXII of IPC

Significance of the study: The significance of the project is to understand and analyse the
sections under chapter XXII of the Indian Penal Code, 1860. The researcher also deals with
various case laws and analyse those case laws which are covered under sections 503 to 510 of
IPC.

Contents/ chapters: (tentative)

1. Introduction to the chapter XXII of IPC


2. Sections contained in chapter XXII of IPC
2.1 section 503 of IPC and its analysis and case laws.
2.2 section 504 of IPC and its analysis and case laws.
2.3 section 505 of IPC and its analysis and case laws.
2.4 section 506 of IPC and its analysis and case laws.
2.5 section 507 of IPC and its analysis and case laws.
2.6 section 508 of IPC and its analysis and case laws.
2.7 section 509 of IPC and its analysis and case laws.
2.8 section 510 of IPC and its analysis and case laws.
3. Relevancy of these sections in the era of 21st century
4. Conclusion
5. Bibliography..

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TABLE OF CONTENTS

1. INTRODUCTION----------------------------------------------------------------------------------06

2.PART-A CRIMINAL INTIMIDATION--------------------------------------------------------07

3.PART-B INTENTIONAL INSULT--------------------------------------------------------------13

4.PART-C ANNOYANCE----------------------------------------------------------------------------26

5.PENAL CODE REVIEW COMMITTEE REPORT-----------------------------------------26

6. SUGGESTIONS OF THE STRAITS TIMES-------------------------------------------------27

7. LAW COMMISSION OF INDIA RECOMMENDATIONS-------------------------------27

8. FAMOUS JURISTS ON CRIMINAL INTIMIDATION-----------------------------------29

9. CRIME HEAD-WISE CASES REPORTED UNDER IPC---------------------------------29

10.CONCLUSION-------------------------------------------------------------------------------------30

11.BIBLIOGRAPHY----------------------------------------------------------------------------------30

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INTRODUCTION

Chapter 22 of Indian Penal Code can be divided into three parts- Part A, B and C. Part-A deals
with Criminal Intimidation that covers sections 503,506,507 and 508 IPC. The offence of
Criminal Intimidation is dealt under Section 503 IPC. Section 506 IPC deals with the
punishment for the offence of Criminal Intimidation. Sections 507 and 508 IPC deals with
punishment for aggravated forms of Criminal Intimidation. Part-B deals with Intentional Insult.
It covers those sections dealing with Intentional Insult i.e., sections 504,505 and 509 of IPC.
Section 504 IPC deals with Intentional Insult with intent to provoke breach of peace.
Statements concluding to public mischief are dealt under Section 505 of IPC. Insult with the
modesty of a woman is also covered under this part. Section 509 IPC deals with word, gesture
or act intended to insult the modesty of a woman. Part-C deals with annoyance. It covers
Section 510 of IPC. Section 510 of IPC deals with Misconduct in pubic by a drunken person.

Explanation: A threat to injure the reputation of any deceased person in whom the person
threatened is interested, is within this section and there are two essential ingredients to the
section-

1. There must be a threat of injury to a person, either

i) To his person, reputation or property; or

ii) To the person, reputation or property of anyone in whom that person is interested.

2. The threat must be made with the intent

i) To cause alarm to that person; or

ii) To cause that person to do an act which he is not legally bound to do or

iii) To cause that person to omit to do any act which he is legally entitled to do, as the
means of avoiding the execution of such threat.

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PART-A: CRIMINAL INTIMIDATION

Section 503- Criminal Intimidation:

Whoever threatens another with any injury to his person, reputation or property, or to the person
or reputation of any one in whom that person is interested, with intent to cause harm to that
person, or to cause that person to do any act which he is not legally bound to do, or to omit to
do any act which that person is legally entitled to do as the means of avoiding the execution of
such threat, commits criminal intimidation.1

This means If any person threatens another with injury to his person, property or reputation,
and to avoid that, the other person is made to do an act he is not legally bound to do, or which
caused alarm to that person, then that person is said to have committed criminal intimidation.
It is extending a threat to another, which results in a particular set of actions from the other as
a means of avoiding the threat.2

Section 503 also includes the threat to injure the reputation of any deceased person in whom
the person threatened is interested. The punishment for the offence of Criminal Intimidation is
prescribed in Section 506 I.P.C.

INTERPRETATION OF SECTION 503:

1. Targeting of the Threat

Communication of the threat need not be direct, and in the presence of the complainant- it is
sufficient even if addressed to a third party, so long as it is intended to reach the victim. This
was the case in Romesh Chandra v. State3, where the accused had sent letters to a person X,
threatening to make public nude photographs of his daughter, and thereby injure the reputations
of both of them, unless he was paid ‘hush money’. He was charged and found guilty of criminal
intimidation against both X and his daughter, although the threat had been directly
communicated only to X. In addition, the threat made need not be targeted at any one person

1
Dadan Prasad Abhay, Glossary of Criminal Law [Definitions, Explanations and Interpretations] pg 154.
2
P.S.A Pillai, Criminal Law, pg 955(9th ed.).
3
AIR 1960 SC 154.

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in particular. The offence under this section is made out if the threat is addressed to a class or
group of persons. However, it must be aimed at a “defined and ascertained body of individuals.
In Re A.K. Gopalan4, the accused delivered a speech at a cinema shed, wherein he made
several vulgar comments, strongly critical of the police force. His defence was that these
comments pertained to the police force in general, and were not threats towards any particular
group. This argument was not accepted, and the Court convicted him of criminal intimidation,
holding that he had intended to frighten by threats members of the police force of Malabar, and
especially those stationed at Badagara, where he had made the speech. In a case before the
Bombay High Court, the facts were that a meeting of lady teachers was interrupted by the
accused shouting that the teachers should leave the hall, and that they should be caught by the
hair, kicked on the waist, and pulled out. To the charge of criminal intimidation, the defence
he adopted was that these words were general, and not targeted at a specific individual or group.
The Court struck down this argument, holding that the threats had been addressed to all the
ladies in the hall. To conclude, the section envisages that the threat be targeted at either a
particular person, or a definite group of persons, and that it be communicated, either directly
or indirectly, to such person or group.

In Abraham v State and Another5 the accused is a jeweller at Thirunakkara, Kottayam and
the complainant, the Resident Engineer of the Kottayam Electricity Agency. The current
charges due from the accused to the Electric Co. amounted to more than Rs. 1000/- on 16-11-
1957. The amount was not paid in spite of repeated demands. The complainant therefore took
steps to stop the supply of current. He sent his men to the accuser's shop to remove the fuse
placed inside the building. The men had to return due to the accuser's resistance. On 16-11-
1957 at about 10-30 A. M. they cut the aerial fuse outside the shop and disconnected the current
supply. At about 2 P. M. the complainant went to the accuser's shop and told him that his
conduct in having obstructed the removal of the indoor fuse was not proper. The prosecution
case is that at about 4-30 P. M. the same day the accused trespassed into the complainant's
office attached to the power house with the object of insulting and annoying him and actually
insulted him by the use of obscene language. The accused is alleged to have told the
complainant "Neither your master nor you nor your father will be able to remove the fuse from
my building. All this is mere 'foul gas' to me". "When the charge is an insult by words, the
words must amount to something more than what in English law is called 'mere vulgar abuse'.

4
AIR 1949 Mad 233.
5
AIR 1960 Ker 236

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It abusive language is used in such circumstances that the court comes to the conclusion that it
cannot possibly have been intended, and cannot have been understood by those to whom it was
addressed to have been intended, to be taken literally, the language cannot be held to amount
to an intentional insult." An analysis of the accused's words would show that the first portion
of his remark is mere tall-talk. Though couched in uncultured language, the remark seems to
be nothing more than a pompous boast that no one in this wide world could enter the accused's
shop without his permission6. The latter portion of the sentence comparing the attempts made
by the complainant to remove the fuse to "foul gas" would at worst amount to vulgarity
indicating want of good manners on the part of the accused, but could hardly be characterised
as an insult. Even if the words used by the accused can be considered to be insulting in the
sense that they were derogatory to the dignity of the person to whom they were addressed, the
circumstances under which they were uttered indicate that the accused's intention was nothing
more than to strike a note on which to make a triumphant exit or to have the satisfaction of
having had the last word in a conversation that was not going to his liking. The further question
is whether the accused intended or knew it to be likely that the provocation given by the insult
would cause the complainant to break the public peace or commit some other offence. The
complainant no doubt has given evidence that on hearing the accused's words he was provoked
to resort to some action which he refrained from doing as he wanted to avoid a breach of the
peace. However what is material is not the reaction of the complainant which might vary
according to the sensitiveness of the individual insulted but the intention of the offender to
provoke or his knowledge that he is likely to provoke the person insulted to commit an offence.
In this case it cannot be held that the accused had the necessary intention7. Neither can he be
fixed with the knowledge that the insult was likely to provoke the complainant to commit an
offence, because the circumstances under which the alleged insulting language was used and
the nature of the remark were such that the reaction reasonably to be expected from any
ordinary man and more so from a man of culture and learning like the complainant, can be
nothing stronger than a retort "Talk decently or clear out of my room". In any view it cannot
be held that all the ingredients necessary to constitute an offence under S. 504 have been made
out. The conviction therefore cannot be sustained.

6
R. N. Saxena, Indian Penal Code, pg 631(19th ed. 2012)
7
R. N. Saxena, Indian Penal Code, pg 631(19th ed. 2012)

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2. INJURY TO PERSON, REPUTATION OR PROPERTY

The section requires that the threat be of injury to person, reputation or property. The term
‘injury’ is defined in S. 44 of the IPC as denoting “any harm whatever illegally caused to any
person in body, mind, reputation or property” Therefore, to attract liability under S. 503, the
harm threatened must be illegal. In Priyanath Gupta v. Lal Jhi Chowkidar,8 the President of
a self-constituted Arbitration Court served a notice to the complainant requesting him to be
present at a certain time and place for the settlement of a claim, and stating that if he did not
attend, the suit would be decreed ex parte. It was held that the threat of decree so made was
covered by the section, since “by no legal process or means could make or give effect to such
a decree. In a subsequent decision, the Calcutta High Court stated categorically that S. 503 is
“a section which deals with illegal threats. The requirement of illegal harm has been considered
by the Madras High Court in relation to a threat of social boycott. In that case, the petitioners
were a group of labourers who were trying to improve their conditions of work by going on a
strike9. They had been convicted under S. 506 of the IPC for threatening to enforce a social
boycott against those of their colleagues who refused to strike, and also of threatening to
deprive them of the services of the barber and the washer man. The Court set aside the
conviction, ruling that these were not threats of injury within the meaning of S. 44, and that “if
it is not illegal, then the threat to do it is not punishable under S. 506”

However, in an earlier case before the Allahabad High Court, a threat of picketing (which was
not an offence at the time) was held to fall under the definition of criminal intimidation. The
accused had issued a notice and an agreement to the complainant, a shopkeeper. The notice
held out a threat that the complainant’s shop would be picketed unless he executed the
agreement, under which he would be barred from importing foreign cloth. According to the
above interpretation, this could not amount to criminal intimidation, because the threat of
picketing was not one of ‘illegal harm10’. However, the Court held that “the notice and the
agreement should be taken jointly” On the basis of the fact that the shopkeeper’s business

8
AIR 1923 Cal 590
9
R. N. Saxena, Indian Penal Code, pg 637(19th ed. 2012)

10
Raman Devgan, Criminal Intimidation( January 4, 2020, 11:05 am),
http://devgan.in/ipc/?a=ipc&q=intimidation

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would suffer if he were to cease the import of foreign cloth, it ruled that the accused had been
correctly convicted under S. 506.

II) PERSON, REPUTATION, PROPERTY


The threat in the offence of criminal intimidation must be directed against ‘person, reputation
or property’. These terms have not been precisely defined by the Courts, but their meaning can
be gauged through the following examples.

In Muhammad Ahmad Khan v. Emperor11, a constable served a notice on the accused and
asked him to make an endorsement at the back of the notice, acknowledging its receipt. The
accused proceeded to write something on the back of the notice, and when the constable told
him that nothing but a signature in acknowledgement was to be written, he reacted by throwing
the notice at the constable, and shouting “Go away, otherwise I will break your hands and feet.”
This was held to be an offence under S. 503, as it involved a threat to the person of the officer.
‘Person’ implies simply the “individuality of a human being…bodily form or substance”

3. Threats to persons in whom target is interested

According to S. 503, a threat of injury to the person or reputation of anyone in whom the target
of the threat is interested can amount to criminal intimidation, provided that the rest of the
ingredients are satisfied. This portion of the definition excludes ‘property’, so a threat to the
property of a third party is not within the purview of the section. A threat to the reputation of a
deceased person is specifically included in the section, under the Explanation, provided that
the deceased be someone in whom the target of the threat is interested.

In Q.E. v. Mangesh Jivaji12, an ex-clerk of the Forest Department sent a petition to the
Revenue Commissioner, purportedly written by the inhabitants of certain villages, threatening
to kill a Forest Officer unless he was transferred to another area. It was held that this was not
an offence under S. 503, as the Revenue Commissioner had neither personal nor official interest
in the Forest Officer. A threat of suicide is also not within the section, unless the target of the
threat is interested in the person making it.13

11
AIR 1936 All 171.
12
(1887) I.L.R. 11 Bom 377 cited from K.D. Gaur
13
Nubi Buksh v. Must. Oomra (1866) PR No. 109 of 1866 cited from R. Ranchhodas and D.K. Takore, Ratanlal
and Dhirajlal’s The Indian Penal Code, 28th ed., (Agra: Wadhwa and Company Law Publishers, 1997), 711

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4. Intention of the Offender

The second essential ingredient of the section is that the threat must be made with intent, either
to cause alarm, or to cause the victim to do an act which he is not legally bound to do, or to
abstain from an act he is entitled to perform. The question of whether or not the target of the
threat was in fact alarmed, or whether he or she actually performed or abstained from
performing any act, to avoid the execution of the threat, is immaterial. It is “the intention of the
speaker that has to be considered in deciding whether what he stated comes within the mischief
of S. 503 The Orissa High Court has held that the gist of the offence is “the effect, which the
threat is intended to have upon the mind of the person threatened.” In the case before it, the
Court also stated that “intention is a mental contention, which has to be gathered from the
circumstances of the case.” If the threat is such as would overcome the ordinary free will of a
firm and prudent man, or if, irrespective of the nature of the threat, it is made with the intention
mentioned in the section, then the offence will be made out. Practically, however, the intention
must be gauged from the facts of the case In the case before it, the Court also stated that
“intention is a mental contention, which has to be gathered from the circumstances of the case.”
If the threat is such as would overcome the ordinary free will of a firm and prudent man, or if,
irrespective of the nature of the threat, it is made with the intention mentioned in the section,
then the offence will be made out. Practically, however, the intention must be gauged from the
facts of the case. In Amulya Kumar Behera v. Nabhagana Behera14, the accused was
acquitted on the grounds that a mere expression of words without any intent to cause alarm
would not invite punishment under the section. An example of how intent is determined from
surrounding circumstances is the case of S.S. Sanyal and another v. K.V.R Nair and others,
where the President of a company threatened his employee, saying “your days are numbered”
The Calcutta High Court decided that there was no criminal intimidation here,15 as the “words
are to be understood in the context of the circumstances in which they were uttered”, and under
such an interpretation the President’s words meant simply that the service of the complainant
under the company may be terminated. Although the meaning of the expressions ‘any act which
he is not legally bound to do’ and ‘any act which that person is legally entitled to do’ is clear,
the meaning of ‘alarm’ was investigated in Amulya Kumar’s Case, where the Court held that
though the degree of alarm could vary, it's essential nature was to “unsettle the mind of the

14
1995 CriLJ 3559, 1995 II OLR 97
15
1987 CRI L.J. 2074

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person on whom it operates and take away from his acts the elements of free voluntary action
which alone constitute consent”
Cases:

In Chander Kala v Ram Kishan,16 the complainant (Smt. Chander Kala) was working as a
teacher in a Govt. Middle School and the respondent (Ram Kishan) was the headmaster of the
same school. The accused, after a series of events, called the complainant to his house and
threatened to attack her modesty if she refused to sign three blank papers. And when she did,
he threatened that he will use those signed papers to blackmail her by recording any statement
on the papers, if she refused to act according to his wishes. He was held guilty of the offence
of criminal intimidation.

In Communist Party of India v Bharat Kumar,17 the question before Supreme Court was
that whether the provisions under Section 503 IPC can be attracted in the cases of bandh,
agitations, strikes, etc. The Supreme Court held that if there is any threat to cause injury to
anyone’s person, property or reputation during observance of bandh, strikes or agitations then
it will constitute an offence under Section 503 IPC.

This section does not come into action if there is any threat of social boycott. This is because
the nature of this threat does not satisfy the conditions of Section 503 IPC.18

In Jowahir Pathak v Prabhoo Ahir,19 it was held that if a person threatens another to ruin
him by cases, then he cannot be convicted under this section as there is no offence committed
by him. But, if a person threatens to ruin false cases, then he will be convicted of the offence
of Criminal Intimidation under Section 503 IPC.

PART-B: INTENTIONAL INSULT

PROVOCATION AND INSULT- S. 504 AND S. 509

The Indian Penal Code contains two provisions relating to insults aimed at people other than
public servants. These are S. 504, which deals with provocation of offences, and S. 509, which
defines a specific crime against women, and deals with insults to the modesty of women.

16
Chander Kala v Ram Kishan, AIR 1985 SCC 1968.
17
Communist Party of India v Bharat Kumar, AIR 1998 SC 184.
18
Hanuman Prasad Matadin, AIR 1949 Mad. 546.
19
Jowahir Pathak v Prabhoo Ahir, (1902) 30 Cl. 418.

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SECTION 504

Section 504 of the IPC reads: Whoever intentionally insults, and thereby gives provocation to
any person, intending or knowing it to be likely that such provocation will cause him to break
the public peace, or to commit any other offence, shall be punished with imprisonment of either
description for a term which may extend to two years, or with fine, or with both.

The purpose of this section is to punish those who intentionally use insulting language, with
the object of provoking a breach of the peace. The section has three essential ingredients-

1. The offender must intentionally insult the complainant.


2. The insult must be such as to provoke the complainant.
The offender must intend, or know it to be likely, that this provocation will cause the
complainant to break the public peace, or commit any other offence.

Interpretation of Section 504

1. ‘Intentional Insult’

The first ingredient of the offence is that there must be an ‘intentional insult’. The insult
referred to in the section need not be in the form of spoken words- it may be written, or it may
arise from the conduct and actions of the accused.20 However, irrespective of its form, not every
kind of abusive language can be classed as an ‘intentional insult’. In Philip
Rangel v. Emperor21, the accused was a shareholder of the Central Telegraph Office Credit Co-
operative Bank Limited, who muttered the words -‘you bloody bastards and cads’, upon being
expelled from a shareholders’ meeting. In considering whether this was an ‘intentional insult’,
Beaumont C.J. held that “when the charge is an insult by words, the words must amount to
something more than what in English law is called ‘mere vulgar abuse’. If abusive language is
used in such circumstances that the Court comes to the conclusion that it cannot possibly have
been intended, and cannot have been understood by those to whom it was addressed to have
been intended to be taken literally, the language cannot be held to amount to an intentional
insult.”

2. The Manner of Insult

The manner of insult covered in the section extends to words, sounds, gestures, the exhibition
of objects and the intrusion upon the woman’s privacy. Of these, the two types of insult that

20
Habib Khan v. Mazharul Haque AIR 1917 Pat 658.
21
AIR 1932 Bom 193

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will be considered here are the exhibition of objects, and the intrusion upon privacy. The words
‘exhibits any object’ do not imply that the object must be displayed to the complainant, in the
presence of the accused. The meaning of this phrase was gone into by the Bombay High Court
in Emperor v. Tarak Das Gupta22. The accused had been convicted by the trial court under
S. 509 for sending a letter containing indecent overtures to an English nurse. On appeal to the
High Court, he pleaded that his act did not come under the words ‘exhibits any object’. The
Court rejected this argument, and held that just because the accused had not personally shown
the nurse the letter did not mean he had not exhibited it to her. Fawcett J. also held that, while
“the word ‘exhibit’ does ordinarily express the idea of actually showing a thing to a
person…such showing need not be immediate…a thing can be exposed or exhibited to a
person, although at first sight it may be wrapped in something which prevents that person from
actually seeing the object contained in the wrapper.”

Case Laws:

In Tanumal Udham Singh v Emperor,23 a letter was sent to a widow by the accused stating
that her husband owes some money to him during the lifetime of the deceased. He also stated
that if the widow didn’t repay the debt, the accused would recover it from her husband in
heaven. The widow filed a complaint against the accused under Section 508 IPC contending
that the matter in the letter sent by accused created Divine Displeasure to the widow. The court
held that the accused not guilty under Section 508 IPC due to the inapplicability of the section
because to constitute an offence under Section 508, the threat should be that of Divine
displeasure to the victim whereas in this case threat was addressed to the husband of the widow
in Heaven and not to the widow. In another case De Cruz,24 it was held that a person who is
excommunicated by his priest does not become an object of divine displeasure.

Case Laws:

In Abraham v State of Kerala,25 it was held that to constitute an offence under Section 504
IPC, the intention of accused is taken into consideration but does not depend upon the reactions
of complainant. Mere breach of good manners does not constitute an offence.

22
AIR 1926 Bom 159.
23
Tanumal Udham Singh v Emperor, AIR 1944 Oudh 203.
24
De Cruz, (1884) 8 Mad. 110.
25
Abraham v State of Kerala, AIR 1960 Ker 236.

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In Md. Ibrahim v State of Bihar,26 the complainant alleged that the accused forged the sale
deeds of complainant’s property. Upon enquiry, it was found that the accused was alleged to
have said that he will take possession of property as per sale deeds and complainant may do
whatever he likes. The court held that this statement does no amount to insult intended to
provoke breach of peace under Section 504 IPC.

Vulgar and abusive imputation against the chastity of the mother and sister of the complainant
were held to be intentional insult which were likely to provoke breach of public peace and
therefore held to be an offence under Section 504 IPC.27

In Gopal v State,28 it was held that the offence of intentional insult under Section 504 IPC does
not contemplate that breach of public peace must have actually been resulted, where there is
likelihood that the person targeted would commit breach of peace, the section will be
applicable.

OFFENCE OF PUBLIC MISCHIEF- S. 505

Section 505 of the IPC is meant to check and punish the spreading of false and mischievous
news intended to upset the public tranquillity. It was inserted by the Amendment Act 4 of 1898.
Sub clauses (2) and (3) were put in by Act 35 of 1969. The section reads:

Statement conducing to public mischief- (1) Whoever makes, publishes or circulates any
statement, rumour or report-
a) with intent to cause, or which is likely to cause, any officer, soldier, sailor or airman in the
Army, Navy or Air Force of India to mutiny or otherwise disregard or fail in his duty as such;
b) with intent to cause, or which is likely to cause, fear or alarm to the public or to any section
of the public whereby any person may be induced to commit an offence against the State or
against the public tranquillity;
c) with intent to incite, or which is likely to incite, any class or community of persons to commit
any offence against any other class or community,
shall be punished with imprisonment which may extend to three years, or with fine, or with
both.

26
Md. Ibrahim v State of Bihar, (2010) 2 Cri. L.J. 2223 (S.C.).
27
State v Kurban Ali, (1956) Cr LJ 500(Bom).
28
Gopal v State, 1952 Mad. WN 236.

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(2) Statements creating or promoting enmity, hatred or ill-will between classes- Whoever
makes, publishes or circulates any statement or report containing rumour or alarming news
with intent to create or promote, or which is likely to create or promote, on grounds of religion,
race, place of birth, residence, language, caste or community or any other ground whatsoever,
feelings of enmity, hatred, or ill-will between different religious, racial, language or regional
groups or castes or communities, shall be punished with imprisonment which may extend to
three years, or with fine or with both29.
(3) Offence under sub-section (2) committed in place of worship etc.- Whoever commits an
offence specified in sub-section (2) in any place of worship or in any assembly engaged in the
performance of religious worship or religious ceremonies, shall be punished with imprisonment
which may extend to five years and shall also be liable to fine.
Exception: It does not amount to an offence, within the meaning of this section, when the
person making, publishing or circulating any such statement, rumour or report, has reasonable
grounds for believing that such statement, rumour or report is true and makes, publishes or
circulates it in good faith and without any such intent as aforesaid.

This section can be divided into two parts, based on the effect of the news spread-

1. 1. Where the publication is intended to, or is likely to cause mutiny amongst soldiers,
army men and navy persons
2. 2. Where the publication is intended to, or is likely to cause commotion amongst the
public, or induce someone to commit an offence against the state or public tranquillity.
Subsections (2) and (3) were added on the recommendation of the National Integration Council,
to widen the scope of the section, in order to prevent the fomenting of communal and religious
tensions. In the case of Kedar Nath v. State of Bihar30, the Supreme Court considered
whether S. 505 was violative of the fundamental right to freedom of speech and expression
under Art. 19(1)(a) of the Constitution.

The Court ruled that that “each one of the constituent elements of the offence under S. 505 has
reference to, and a direct effe3ct on the security of the State or public order”, and accordingly
that “these provisions would not exceed the bounds of reasonable restrictions on the freedom
of speech and expression”31Therefore, the constitutionality of S. 505 has been upheld under
Clause 2 of Art. 19(1)(a).

29
Prof. S.N. Misra, Indian Penal Code pg 946 (12th ed. 2016).
30
AIR 1962 SC 955

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Kedar Nath Singh V State of Bihar:

• One Kedar Nath Singh a member of the Forward Communist Party in Bihar was involved
in terming the officers of C.I.D as “dogs”, the Indian National Congress as “Goondas”, he
went on saying that he believe in revolution, which will come and in the flames of which
the capitalists, zamindars and the Congress leaders of India, who have made it their
profession to loot the country, will be reduced to ashes and on their ashes will be established
a Government of the poor and the downtrodden people of India. He also targeted Vinobha
Bhave’s attempts to redistribute land.
• Subsequently, Kedar Nath Singh was convicted by the Trial Court under Section 124-A
(Sedition) and Section 505 (Public Mischief) and was sentenced to undergo rigorous
imprisonment for a period of one year. On appeal, a Single Judge Bench of The Patna High
Court comprising Justice Naqui Imam upheld the conviction and accordingly dismissed the
appeal. In his judgement, it was observed by the learned judge that “the subject-matter of
the charge against the appellant was nothing but a vilification of the Government; that it
was full of incitements to revolution and that the speech taken as a whole was certainly
seditious. It is not a speech criticising any particular policy of the Government or criticising
any of its measures.32”
• On further appeal, the matter was placed before a Divison Bench of the Supreme Court
along with a bunch of appeals of the same subject matter from the State of Uttar Pradesh.
As there was an issue of constitutional validity of the Section 124-A and Section 505 of the
Indian Penal Code, the Divison Bench accordingly referred the matter to a Constitution
bench. After examining the impugned provisions by referring to the judicial history of the
same the Apex court was confronted with two conflicting judgements of the Federal Court
in Niharendu Dutt Majumdar v. The King33 (1942) F.C.R. 38 and The Privy Council in
King-Emperor v. Sadashiv Narayan Bhalerao I.L.R. (1947) IndAp 89.
• While dealing with these two judgments, the Hon’ble Supreme Court was of the opinion
that if the judgement and interpretation of the Federal Court are accepted then the impugned
sections would come within the ambit of permissible legislative restrictions on the
fundamental right of freedom of speech and expression. On the other hand, if the judgement
and interpretations of the Privy Council be accepted then the impugned sections are liable
to be quashed as unconstitutional in view of Article 19(1)(a) read with Article 19(2). In this

32
P.S.A Pillai, Criminal Law pg 1273(10th ed. 2008).
33
AIR 1939 Cal 703

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manner, the scope of the impugned sections was restricted and the Constitutional validity
of both the impugned sections was upheld. Accordingly, the appeal was dismissed and
appeal of other connected matter was remanded back to the concerned High Court.
The Apex Court while perusing the conflicting decisions of the Federal Court and The Privy
Council was of the opinion that if the interpretation of Privy Council that even without any
tendency to disorder or intention to create disturbance of law and order, by the use of words
written or spoke which merely create disaffection or feelings of enmity against the Government,
the offence of sedition is complete, then such an interpretation of the sections would make then
unconstitutional in view of Art. 19(1)(a) read with clause (2). Accordingly the interpretation of
the Federal Court that that the gist of the offence of ‘sedition’ is incitement to violence or the
tendency or the intention to create public disorders by words spoken or written, which have the
tendency or the effect of bringing the Government established by law into hatred or contempt
or creating disaffection in the sense of disloyalty to the State was accepted and the Section was
given a restrictive interpretation.
Strict construction in favour of defence
The Orissa High Court, in Kalicharan Mohapatra v. Srinivas Sahu34 held that S. 505 must
be construed strictly in favour of the defence, in view of the fact that it deals with the liberty
of the subject. In that case, the accused were charged under S. 505(c) for the publication of a
pamphlet which was critical of the administration of Talcher Town. The Court held that the
contents of the pamphlet did not fall under S. 505 (c), as it did not incite any offence, and that
“in a democratic setup a citizen has a right, subject to certain restrictions, to point out, either
by means of a pamphlet or by holding public meetings, what he considers to be
the…commission and omission on the part of the officials…in consequence of which the public
of that place are suffering.The Court also held that under the exception to S. 505, a person is
granted immunity from prosecution if he has reasonable grounds for believing the allegations
to be true, and if he lacks the intent required by the section.

Mens Rea

The offence under S. 505(2) has been held to require mens rea by the Supreme Court, in Bilal
Ahmed Kaloo v. State of Andhra Pradesh35. The Court held that the words ‘with intent to
create or promote or which is likely to create or promote’ inserted a requirement of mens rea.

34
AIR 1960 Orissa 65.
35
(1997) 7 SCC 431.

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Since these phrases occur in every clause of S. 505, mens rea is an essential ingredient of the
section. In a recent case before the Madras High Court, K.P.S. Sathyamoorthy v. State of
Tamil Nadu36, it was alleged that the accused had committed an offence under S. 505(2) for
publishing a circular in a Tamil daily wherein he had criticized Christians for converting to
Hinduism, so as to enjoy job opportunities. The Court rejected this allegation, holding that,
firstly, the statement was a fact, and secondly, that “intention is the pre-condition for the
commission of the offence” under S. 505(2), which intention had not been made out on the
facts.By interpreting S. 505 so as to require intention as a pre-condition, the Courts have again
sought to ensure that it is not used against those who, in the exercise of their constitutional right
to free speech, innocently cause public disorder.37It is evident from the interpretation given by
the Courts that S. 505 is to be construed in the defiance's favour, and applied sparingly. At the
same time, its constitutionality in the face of Art. 19(1)(a) has been upheld by the Supreme
Court- this makes it a valuable tool in the fight against communalism, among other evils. It is
submitted that the Courts have been successful in striking a balance between the conflicting
demands of freedom of speech and public order.

SECTION 506- PUNISHMENT FOR CRIMINAL INTIMIDATION


Whoever commits the offence of criminal intimidation shall be punished with imprisonment
of either description for a term which may extend to two years, or with fine, or with both. If
threat to be cause death or grievous hurt etc or cause the destruction of any property by fire or
to cause an offence punishable with death or( imprisonment for life), or with imprisonment for
a term which may extend to 7 years, or to impute, unchastity to a woman, shall be punished
with imprisonment of either description for a term which may extend to seven years, or with
fine or with both.

Ingredients of the offence;

The essential ingredients of section 506 are as follows:

• The accused threatened someone with injury to his person, reputation or property or the
person, reputation and or the property of another in whom the former was interested.
• The accused did so with the intent to cause alarm to the victim of offence.

36
MANU/TN/0216/2003
37
http://www.shareyouressays.com/115791/speech-on-criminal-intimidation-insult-and-annoyance

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• He did so to cause the victim to perform any act which he was not legally bound to do.

Threat causing alarm:


The meaning of the term “Alarm” was examined in the case Amulya Kumar Behera v.
Nabhagana Behera. It was held that intention must to be cause alarm to the victim and whether
he is alarmed or not is really of no consequence. But material has to be brought on record to
show that intention to cause alarm would not be sufficient to bring an application of Section
506 of IPC. The gist of the offence is the effect, which the threat is intended to have upon the
mind of the person threatened. Before it can have effect on his mind it must be either made to
him by the person threatening or communicated to him in some way.

Cases:

In Ramesh Chandra Arora v State,38 the accused was held guilty of Section 503 IPC
punished under Section 506 IPC.

For the offence to constitute under Section 506 IPC, the grounds under Section 506 must be
satisfied to convict a person. In Saraswati v Tamil Nadu,39 the accused merely asked a person
not to work in a private garden and go away from there and threatened to thrash him if he does
not leave. The court acquitted the person stating that the grounds for invoking section 506 IPC
and for convicting the accused under Criminal Intimidation are not sufficient as it was a mere
warning without any intention to cause any harm or injury to the complainant.

In State of Himachal Pradesh v Prem Singh,40 on the allegation that the respondent had
sexually ravished the complainant and had outraged the modesty of not only complainant, but
of several other girl students of the school where the respondent was a teacher, law was set in
motion. The respondent was further charged for commission of offences relating to threatening
the prosecutrix with dire consequences in case she disclosed the incident to somebody else.
The accused was held guilty under Sections 506 along with other relevant sections and
sentenced him to two years and six months imprisonment under Section 506 IPC.

38
Ramesh Chandra Arora v State, AIR 1960 SC 154.
39
Saraswati v Tamil Nadu, 2002 Cr LJ 1420 (Mad).
40
State of Himachal Pradesh v Prem Singh, AIR 2009 SC 1010.

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SECTION 507- CRIMINAL INTIMIDATION BY AN ANONYMOUS
COMMUNICATION
Whoever commits the offence of criminal intimidation by an anonymous communication, or
having taken precaution to conceal the name or abode of the person from whom the threat
comes, shall be punished with imprisonment of either description for a term which may
extend to two years, in addition to the punishment provided for the offence by the last preceding
section41.

Ingredients of the offence;

The ingredients of the offence under Section 507 are the ingredients of Section 506. The
essential ingredients to constitute an offence under Section 507 are:

• The accused threatened someone with injury to his person, reputation, or property or to
the person, reputation of any one in whom the former was interested.
• The accused did so with intent to cause alarm to the said person
• The accused caused the victim to perform any act which has not legally bond to do.
• The accused made the threat by anonymous communication sent to the victim of
offence.

This section expressly provides that punishment under this section will be in addition to
whatever punishment has been imposed on the accused under proceeding Section 506 of IPC.
Thus, this section is a corollary to the previous section and can be said to be an aggravated
form of intimidation. As already stated, the punishment for the offence under this section is
two years imprisonment in addition to the punishment under previous Section 506 of IPC. The
offence committed under this section is non-cognizable bailable and non-compoundable. It is
triable by Magistrate of the first class.

41
R.N Saxena, Indian Penal Code pg 639(19th ed. 2012).

22 | P a g e
508. ACT CAUSED BY INDUCING PERSON TO BELIEVE THAT HE WILL BE
RENDERED AN OBJECT OF THE DIVINE DISPLEASURE.

Whoever voluntarily causes or attempts to cause any person to do anything which that person
is not legally bound to do, or to omit to do anything which he is legally entitled to do, by
inducing or attempting to induce that person to believe that he or any person in whom he is
interested will become or will be rendered by some act of the offender an object of Divine
displeasure if he does not do the thing which it is the object of the offender to cause him to do,
or if he does the thing which it is the object of the offender to cause him to omit, shall be
punished with imprisonment of either description for a term which may extend to one year, or
with fine, or with both42.

Illustrations-
(a) A sits dharna at Z’s door with the intention of causing it to be believed that, by so sitting,
he renders Z an object of Divine displeasure.43 A has committed the offence defined in this
section.(b) A threatens Z that, unless Z performs a certain act, A will kill one of A’s own
children, under such circumstances that the killing would be believed to render Z an object of
Divine displeasure. A has committed the offence defined in this section.

Ingredients of the offence; The essential ingredients of the offence under Section 508 are:

• The accused voluntarily caused or attempted to cause any person to do anything which
that person is not legally bound to do or omit to do a thing which he is legally bound to
do.

• The accused induced that person to believe that either he himself or any person
interested in him become an object of divine displeasure unless such thing was so done.

42
P.S.A Pillai, Criminal Law pg 1273(10th ed. 2008).
43
P.S.A Pillai, Criminal Law, pg 977(9th ed.).

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Case Laws:

In Tanumal Udham Singh v Emperor,44 a letter was sent to a widow by the accused stating
that her husband owes some money to him during the lifetime of the deceased. He also stated
that if the widow didn’t repay the debt, the accused would recover it from her husband in
heaven. The widow filed a complaint against the accused under Section 508 IPC contending
that the matter in the letter sent by accused created Divine Displeasure to the widow. The court
held that the accused not guilty under Section 508 IPC due to the inapplicability of the section
because to constitute an offence under Section 508, the threat should be that of Divine
displeasure to the victim whereas in this case threat was addressed to the husband of the widow
in Heaven and not to the widow.

In another case De Cruz,45 it was held that a person who is excommunicated by his priest does
not become an object of divine displeasure.

SECTION 509- WORD, GESTURE OR ACT INTENDED TO INSULT THE


MODESTY OF WOMAN

Whoever, intended to insult the modesty of any woman, utters any word, makes any sound or
gesture, or exhibits any object, intending that such word or sound shall be heard, or that such
gesture or object shall be seen, by such woman, or intrudes upon the privacy of such woman
shall be punished with simple imprisonment for a term which may extend to one year, or with
fine or with both.46

The object of this section is to protect the modesty of a woman and to curb any aggression
which intents to outrage the modesty of woman.

Sec 509 IPC is one of the most important sections of the Indian Penal Code. The object of this
section is to protect the modesty and chastity of a woman. To establish an offence under this
section, a person requires the following essential elements. These are as follows:

44
Tanumal Udham Singh v Emperor, AIR 1944 Oudh 203.
45
De Cruz, (1884) 8 Mad. 110.
46
P.S.A Pillai, Criminal Law pg 1275(10th ed. 2008).

24 | P a g e
• Intention to insult the modesty of a woman,
• The insult must be caused-

1. by uttering some word, or making some sound, or gesture or exhibiting any object or
so as to be heard or seen by such woman, or
2. by intruding upon the privacy of such woman.
3. Case Laws:

In Re Tarak Das Gupta,47 a letter by post was sent by accused to an unmarried nurse
containing indecent overtures. They have no acquaintance with each other. It was held that the
accused guilty under Section 509 IPC as he insulted the modesty of the nurse by exhibiting the
object irrespective of the fact that the letter was in a closed envelope and sent through an agent
called post office. It is not necessary that the offender himself should personally exhibit the
object. The question before Supreme Court in the case State of Punjab v Major Singh48 was
whether the age is a relevant factor to consider the offence under Section 509 and whether the
offender can be held guilty for outraging the modesty of woman if the victim is not conscious
about the offensive act being committed on her. Whether the modesty of an infant child can be
outraged or not is also answered in the present case. In the above case, the offender entered a
room of 7 ½ month old infant female and outraged the modesty of that infant. It was held that
the act of outraging the modesty of a woman was not limited by the age of the victim and
whether the victim knew or was conscious about the offensive act being committed on her. The
reaction of the woman is very relevant, but its absence is not always decisive. So the accused
was convicted for the offence of outraging the modesty of a woman under relevant sections of
IPC. The Supreme Court in the case J Jaishankar v Government of India49 held that the
conviction of the offender under Section 509 IPC involved moral turpitude.

In Bankey v State of U.P50 the accused was held guilty under Section 509 IPC for outraging
the modesty of a woman by entering the room of that woman in the night when she was sleeping
alone in an attempt to have sexual intercourse and stood naked before her and also held that
intrusion upon the privacy of the woman if sufficiently proved can constitute an offence under
Section 509 IPC. However he was not held guilty for attempt to rape.

47
Re Tarak Das Gupta, AIR 1926 Bom 159.
48
State of Punjab v Major Singh, AIR 1967 SC 63.
49
J Jaishankar v Government of India, 1996(6) SCC 204.
50
Bankey v State, AIR 1961 All 131.

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PART-C: ANNOYANCE

SECTION 510- MISCONDUCT IN PUBLIC BY A DRUNKEN PERSON

Whoever, in a state of intoxication, appears in any public place, or in any place which it is a
trespass in him to enter, and there conducts himself in such a manner as to cause annoyance to
any person, shall be punished with simple imprisonment for a term which may extend to
twenty-four hours, or with fine which may extend to ten rupees, or with both51,

Ingredients of the offence;

The essential ingredients to constitute an offence under Section 510 IPC are:

1) The accused must have appeared at a public place (or at other place by committing a
trespass);
2) He must be drunk; and
3) He must have conducted himself in such a manner as to cause annoyance to some
person.52

Penal Code Review Committee Report:

The Penal Code Review Committee Report is submitted on the month of August in the year
2018 to the Minister for Home Affairs and Minister for Law. The member of the committee
includes ministers, Judges of Supreme Court, Professors from various Law Schools across
Globe, etc. The objective of the Committee is to conduct a thorough and comprehensive review
of the Penal Code, and make recommendations on reforming the Penal Code.

The Committee categorized the recommendations into seven chapters in which ‘updating the
penal code’ is one among them. One of the recommendations says to amend Section 506 IPC
(Criminal intimidation) ‘to remove reference to imputation of unchastity to a woman’ to update
the archaic language. This is because Acts involving “imputing chastity to a woman” included
examples such as threatening to release obscene pictures of a woman to the public. The
enhanced punishment for “imputing unchastity to a woman” probably reflected societal norms
at the time, where the reputational damage of imputing unchastity to a woman was higher than

51
P.S.A Pillai, Criminal Law, pg 977(9th ed.).
52
P.S.A Pillai, Criminal Law, pg 977(9th ed.).

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it is today. It also recommended to introduce a new offence criminalising the placing of any
article in any place whatever, or dispatching any article by post or any means whatever of
sending things from one place to another, with the intention of inducing in any person a belief
that this article is likely to cause hurt or damage to property by any means. It shall not be
necessary for the offender to have any particular person in mind in whom he intends to induce
the relevant belief.53

Another recommendation “Sexual exposure” is a sexual offence, and ought to be listed under
Chapter XVI of the Penal Code (in the sub-Chapter on Sexual Offences), instead of Chapter
XIV (Offences affecting the public tranquillity, public health, safety, convenience, decency
and morals) or Chapter XXII (Criminal intimidation, insult and annoyance).54

Suggestions of The Straits Times:

The spokesperson to the Straits Times suggested that the Section 509 IPC, which speaks only
about women, should also include other genders stating that “men as well as women deserve
protection against offensive sexual speech, gestures and intrusions into privacy.”55 He stated
that section 509 IPC should not be limited to women and suggested that instead of defining the
offence in terms of modesty, a gender-neutral phrase such as "word or gesture of a sexual nature
intended to offend" could be used.

Law Commission of India- recommendations:

The Law Commission of India prepared a report called Forty- Second report on Indian Penal
Code in the year 1971 on the month of June and made recommendations on some of the
provisions of Indian Penal Code.

The Law Commission of India recommended to insert a new section 506-A which states
“Threat of suicide with intent to coerce a public authority- Whoever holds out a threat of suicide
a public authority, with intent to cause that authority to do any act which it is not legally bound
to do, or to omit to do any act which it is legally entitled to do, as the means of avoiding the
execution of such threat, and does any act towards the execution of such threat, shall be
punished with imprisonment of either description for a term which may extend to three years

53
Penal Code Review Committee report, pg. 71
54
Penal Code Review Committee report, pg. 87
55
https://www.straitstimes.com/singapore/law-adopted-from-1860-indian-penal-code

27 | P a g e
or with fine or with both.” and also to make the offence cognizable and triable by a Magistrate
of the First Class. It also recommended to revise section 504 as “Intentional insult with intent
to provoke breach of the peace- Whoever intentionally insults any person, intending or
knowing it to be likely that such insult will provoke that person to break the public peace or to
commit any other offence, shall be punished with imprisonment of either description for a term
which may extend to two years, or with fine, or with both.” This is recommended to bring out
more directly the connection between the insult and the breach of peace. The other
recommendation made by the Law commission was to remove section 505 because that section
can be covered under the offences against public tranquillity and can be covered in Chapter 8
as section 158 B. The commission also recommended to omit Section 510 IPC stating that in
areas where Section 54 of Police Act is not applicable, there is hardly any need of section 510
IPC as such misconduct is not noticeable.

156th Law Commission Report, 1997:

The Law Commission of India in its 156th report submitted on August in the year 1997 gave
some recommendations on various provisions of IPC of which it recommended to insert a new
section 507A. According to the report, Section 507A states:

Whoever Affixes to, or inscribes or exhibits on, any place open to public view any
objectionable matter, or Damages, destroys or defaces any place open to public view, Shall be
punished with imprisonment of either description for a term which may extend to two years,
or with fine, or with both. The report also suggested to amend Section 510 IPC which deals
with Misconduct in public by drunken person. It recommends to enhance the quantum of
punishment from “with simple imprisonment for a term which may extend to twenty- four
hours, or with fine which may extend to ten rupees or with both” to “with imprisonment till
rising of the court or with fine which may extend to one hundred rupees”.56

56
156th Law Commission Report.

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FAMOUS JURIST ON CRIMINAL INTIMIIDATION

Crime is a changing phenomenon dependent upon the social development of a people that is
upon the fundamental rights interests and values dominating their criminal beliefs. Due to the
different common belief the conflict arise among the individuals to resolve the conflict the set
patent rule is require therefore the laws develops in every society.

Sir Henry Maine in his book ‘Ancient Law’ has stated that the penal law of ancient
communists was not the law of crimes; but was the law of wrongs. The person injured
proceeded against the wrongdoer by an ordinary civil actions and recovered compensation in
the shape of money, if he succeeded

Crime head-wise cases during reported under Indian Penal Code (IPC)
during 2018:

A report was prepared by the government of India and is also available in the website
data.gov.in. The source of the report prepared by the Government of India is Crime in
India,2018- National Crime Rewards Bureau (NCRB). The granularity of the record is
annual. A total of 8,02,267 cognizable crimes comprising 5,45,502 Indian Penal Code (IPC)
crimes were registered in 19 metropolitan crime cities during 2018, showing an increase of
10.0% over 2017( 7,29,174 cases). During 2018 IPC crimes have increased by 3.5% and have
increased by 27.1% over 2017. Percentage share of IPC was 68.0% during 2018.

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Conclusion

We can conclude that there are certain offences which do not affect anybody physically but they
are still punishable of which the best example is Criminal Intimidation, Insult and Annoyance under
Chapter 22 of Indian Penal Code. Although these offences seem straight-forward, there are several
ways in which one can commit them. The punishment for these offences may include
imprisonment for up to 7 years depending on its nature.

BIBLIOGRAPHY

1) Glossary of criminal law


2) Merriam- Webster Dictionary
3) https://www.manupatrafast.com/
4) www.scconline.com
5) www.westlaw.com
6) P.S.A Pillai, Criminal Law

7) R.N Saxena, Indian Penal Code.

8) http://devgan.in/ipc/?a=ipc&q=intimidation
7) Prof. S.N Mishra, Indian Penal Code
10) https://www.straitstimes.com/singapore/law-adopted-from-1860-indian-penal-code

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