Karnataka High Court Refuses to Quash FIR in Trial Room Voyeurism Case, Says “No Woman Safe”
In a strong and unequivocal order dated January 27, 2026, the Karnataka High Court refused to quash a First Information Report (FIR) registered against a man accused of attempting to take photographs of a woman while she was changing clothes inside a trial room of a clothing store in Bengaluru. The Court underlined the gravity of the allegations and observed that if such conduct is ignored, “no woman is safe.”
The case relates to an incident that allegedly occurred in 2024, when a 28-year-old woman entered a trial room in a textile shop to try on clothes. According to the complaint, the woman noticed a gap in the trial room door and suspected that someone was attempting to take photographs of her while she was changing. Upon raising an alarm, it was discovered that a shop employee had allegedly tried to capture images using his mobile phone.
Following the complaint, police registered an FIR under Section 77 of the Bharatiya Nyaya Sanhita, 2023, which deals with the offence of voyeurism, criminalising the act of capturing or attempting to capture images of a woman engaged in a private act without her consent.
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Petition Seeking Quashing of FIR
The accused approached the Karnataka High Court seeking quashing of the FIR and a stay on the investigation by invoking the Court’s inherent powers. The defence argued that a chargesheet had already been filed and pointed out that the accused was 19 years old at the time of the alleged incident. It was further submitted that even if the phone had been used, no incriminating material remained as the alleged images were deleted.
Court’s Strong Observations
Justice M. Nagaprasanna firmly rejected the plea and made strong oral observations while dismissing the request for relief. The Court stated:
“The woman gets into a trial room and you shoot! How can any clothes store be safe for a woman if you go on shooting through the curtains?… Case is of voyeurism. We will not spare such people. Even if an allegation comes that in the trial room, you have kept a camera… no woman is safe.”
The Court further noted that deletion of images or absence of recovered material does not dilute the seriousness of the allegation. Emphasising that such matters must be tested at trial, the Court observed:
“By the time she (complainant woman) came out to take the phone, you (may have) deleted… If chargesheet has been filed, go seek discharge… Everything depends on trial. If people go on keeping phones in the trial room, who is safe?… Even if you argue for 10 hours, I am not going to entertain.”
The Bench declined to interfere with the investigation and allowed the accused to withdraw the petition, granting liberty to pursue remedies before the trial court.
Legal Position on Voyeurism
Section 77 of the Bharatiya Nyaya Sanhita criminalises voyeurism, which includes watching or capturing images of a woman while she is engaged in a private act, such as changing clothes, where she has a reasonable expectation of privacy. The provision reflects the legislature’s intent to safeguard women’s dignity, privacy, and bodily autonomy.
Significance of the Ruling
The ruling sends a strong message that courts will not lightly interfere in cases involving alleged invasion of privacy and sexual misconduct against women, especially at the pre-trial stage. It reinforces the judiciary’s commitment to ensuring that allegations of voyeurism are dealt with seriously and adjudicated through a full trial process.
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