Delhi High Court in Varun Bhatia vs. State &Anr. [Criminal Revision Petition No. 1032 of 2018] on August 28, 2023 examined the issue as to whether the utterance of the term ‘Gandi Aurat’ by a male against a female shall be amounted to a charge of outraging of her modesty, under Section 509 of Indian Penal Code, discharged the accused (male individual) after placing reliance on the (a) facts that the complainant and the accused were in the capacity of employee and superior officer respectively and there was no mention apart from a single word that the accused had called her dirty woman and (b) conduct of the complainant herself who was not attending the office and were not even replying to the official mails which was of a great concern to the accused who was the superior officer of the complainant. Additionally, the Court based its findings due to the reason that there was no evidence of any behavior on the part of the accused indicating that he persisted in any unwanted social conduct.
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