Allahabad High Court Quashes Charges Against Seema Beg in Child Labour Case

Court Finds No Prima Facie Evidence of Human Trafficking or Bonded Labour in Case Involving Minor Domestic Workers

In a significant ruling, the Allahabad High Court on October 7, 2025, quashed the cognizance order and charge-sheet against Seema Beg, who was accused of employing minor girls as domestic helpers under exploitative conditions. The court found no prima facie evidence to support charges under Sections 143 of the Bharatiya Nyaya Sanhita (BNS), Section 79 of the Juvenile Justice (Care and Protection of Children) Act, 2015, and Sections 4 and 16 of the Bonded Labour System (Abolition) Act, 1976.

The case, which attracted considerable attention due to allegations of human trafficking and bonded labor, involved two minor girls employed in the household of Seema Beg and her husband, Zahid Jamal Beg. The FIR filed on September 13, 2024, alleged that one of the minors had died under suspicious circumstances, prompting an investigation that led to the filing of charges against the couple.

Presiding Judge Sameer Jain analyzed the material collected during the investigation, concluding that the allegations did not establish exploitation or coercion necessary to substantiate the charges. The court emphasized that mere employment of minors, without evidence of recruitment for exploitation through threats, force, or inducement, does not amount to human trafficking under Section 143 BNS.

The court also addressed the applicability of Section 79 of the Juvenile Justice Act, noting that there was no evidence of the minors being kept in bondage or having their earnings withheld for the benefit of the accused. Similarly, the court found no grounds for charges under the Bonded Labour Act, as there was no compulsion or enforcement of bonded labor by the accused.

Citing precedents from Supreme Court judgments, the court reiterated the principle that prosecution should not proceed in the absence of prima facie evidence, aligning with the rulings in R.P. Kapur v. State of Punjab and State of Haryana v. Bhajan Lal.

The court's decision to quash the charges underscores the importance of substantiating allegations with concrete evidence before proceeding with criminal prosecution. This ruling is likely to have implications for similar cases, emphasizing the need for thorough investigation and evidence collection in allegations of human trafficking and labor exploitation.

Bottom Line:

Application for quashing cognizance order and charge-sheet under Sections 143 BNS, 79 Juvenile Justice (Care and Protection of Children) Act, 2015, and Bonded Labour System (Abolition) Act, 1976 - Court held that prima facie no offences are made out against the applicant.

Statutory provision(s): Bharatiya Nyaya Sanhita, 2023 Section 143; Juvenile Justice (Care and Protection of Children) Act, 2015 Section 79; Bonded Labour System (Abolition) Act, 1976 Sections 4, 16

Seema Beg v. State of U.P., (Allahabad) : Law Finder Doc Id # 2805842