https://www.scconline.com/blog/post/2023/01/28/section-438-crpc-bombay-high-court-abuses-given-on-phone-cannot-be-said-to-be-within-public-view-to-attract-the-ingredients-of-offence-punishable-under-atrocities-act/
[Section 438 CrPC] Bombay High Court | Abuses given on phone cannot be said to be within public view to attract the ingredients of offence punishable under Atrocities Act