Matrimonial Vendetta: MP High Court Quashes FIR Against Husband and Family
The Madhya Pradesh High Court quashed an FIR filed against a man and his family members under Sections 354(A), 354(B), 376 , 323, 294 , 506, 34, and 498 of the Indian Penal Code (IPC), as well as Sections 3 and 4 of the Dowry Prohibition Act, 1961. The FIR was lodged by the wife, alleging that she was subjected to harassment and cruelty by her husband and his family members. However, the Court observed that the complaint appeared to be motivated by a desire for revenge rather than genuine accusations, and it was lodged as a counteraction to ongoing civil litigation.
The petitioners filed the motion under Section 482 of the Criminal Procedure Code (Cr.P.C.), seeking the quashing of the FIR and the subsequent proceedings. Justice Subodh Abhyankar, delivering the ruling, found that the petitioners were falsely implicated due to a matrimonial dispute between the wife and the husband. The Court held that continuing the trial would only result in the abuse of the judicial process, as the allegations appeared to be an attempt to retaliate against the petitioners in response to their ongoing divorce proceedings.
According to the FIR, the complainant and the petitioner had a love marriage in 2020, both working as teachers in an engineering college. She alleged that after the marriage, her in-laws began harassing her, demanding more dowry, although her family had already spent over Rs 10 lakh on the wedding. Additionally, the wife accused her mother-in-law of forcibly taking her ornaments. She further claimed that she was subjected to unnatural intercourse by her husband, and her husband’s brother allegedly outraged her modesty and verbally abused her. The FIR also mentioned that her husband tore her clothes, recorded a video of her, and sold her to another man for Rs 2 lakh, claiming that she should live in an ashram with the said individual.
The Court noted a significant delay of at least four months in lodging the FIR after the events, and emphasized that apart from the verbal allegations, there was no material to substantiate the claims. It also pointed out that the wife and the petitioners were educated professionals, and the timing of the FIR seemed linked to the divorce petition filed by the husband in February 2021, with the FIR lodged shortly thereafter in March 2021. The Bench noted that this appeared to be a retaliatory action, an attempt to undermine the husband's case in the ongoing civil matters.
In light of these factors, the Court concluded that the petitioners had been falsely implicated and that the continuation of the trial would amount to an improper use of judicial proceedings. The High Court, therefore, quashed the FIR, ruling that the accusations lacked merit and were primarily driven by personal vendetta.
Cause Title: Aman and Others v. The State of Madhya Pradesh and Others
Case No: MISC. CRIMINAL CASE No. 19771 of 2024
Citation: MCRC No. 19771-2024
Date: November-13-2024
Bench: Justice Subodh Abhyankar
[Read/Download order]
