Kiran Raj

The Supreme Court of India Division Bench of Justice B.V. Nagarathna and Justice R. Mahadevan quashed an FIR lodged by a wife against her brother-in-law under Sections 323 and 498A of the Indian Penal Code and Sections 3 and 4 of the Dowry Prohibition Act. Highlighting that allegations in matrimonial disputes must be assessed with care and in light of pragmatic realities, the Court found the accusations of dowry harassment and cruelty to be vague and unsupported by specific instances. Stressing the need to prevent miscarriage of justice and abuse of criminal process, the Court held the continuation of proceedings against the appellant unwarranted.

The case arose from a complaint lodged on 9 November 2023 by a woman against her husband, mother-in-law, and brother-in-law, alleging cruelty and dowry-related harassment. She stated that within ten days of her marriage to the husband in May 2014 she was subjected to demands for dowry and harassment. She further alleged that in December 2022, owing to such harassment, she suffered a burst vein in her brain leading to paralysis of her right hand and leg. She also claimed that she was compelled to sign a consent letter in the presence of her relatives before being allowed to reside in her matrimonial home.

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The FIR was registered at Civil Lines Police Station, Meerut, under Sections 323 and 498A of the Indian Penal Code and Sections 3 and 4 of the Dowry Prohibition Act. The accused, including the husband, mother-in-law, and the appellant-brother-in-law, approached the Allahabad High Court seeking quashing of the FIR. The High Court declined to quash the proceedings, observing that the FIR disclosed a prima facie cognizable offence.

In the Supreme Court, the appellant contended that the allegations against him were vague and omnibus, lacking specific dates, places, or acts linking him to the alleged cruelty or injury. It was argued that the FIR did not disclose the essential ingredients of the offences alleged and that the continuation of the criminal proceedings would amount to abuse of process.

The respondent-wife supported the allegations made in the FIR. The State defended the continuation of investigation and proceedings.

The Supreme Court examined the FIR, the nature of allegations, and relevant provisions of law, including Sections 323 and 498A IPC and Sections 3 and 4 of the Dowry Prohibition Act. Finding the allegations against the appellant to be general and lacking particulars, the Court quashed the FIR and all consequent proceedings as against him alone.

The Bench stated: “A bare perusal of the FIR shows that the allegations made by complainant/respondent No.2 are vague and omnibus.” It further noted: “Other than claiming that the husband and his family along with the accused/appellant herein mentally harassed her with a demand for dowry, the complainant/respondent No.2 has not provided any specific details or described any particular instance of harassment.”

On the allegation of physical harm, the Court stated: “The complainant/respondent No.2 has failed to impress the Court as to how the alleged harassment has any proximate relationship to the said injury and nerve damage that she sustained, so as to punish her in-laws under Section 323 IPC.” The Bench further recorded: “There is no remote or proximate act or omission attributed to the accused/appellant that implicates him or assigns him any specific role in the said FIR for the offence of hurt as defined under Section 319 IPC.”

On the charge under Section 498A IPC, the Court noted: “Merely stating that the accused/appellant has mentally harassed the complainant/respondent No.2 with respect to a demand for dowry does not fulfill the ingredients of Section 498A of IPC specially in absence of any cogent material or evidence on record to substantiate the said allegations. The term ‘cruelty’ cannot be established without specific instances.”

The Court stressed the need for precision in matrimonial disputes, recording: “Courts have to be careful and cautious in dealing with complaints and must take pragmatic realities into consideration while dealing with matrimonial disputes where the allegations have to be scrutinized with great care and circumspection in order to prevent miscarriage of justice and abuse of process of law.”

Referring to State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335, the Court cited paragraph 102 which lists illustrative categories where FIRs may be quashed, including situations where allegations are vague, improbable, or mala fide. Applying this test, the Court observed: “On a careful consideration of the aforementioned judicial tests, we find that none of the offences alleged against the accused/appellant herein is made out.”

The Court also cited Dara Lakshmi Narayana v. State of Bihar, (2025) 3 SCC 735, reiterating that sweeping allegations against family members in matrimonial disputes must be curbed: “A mere reference to the names of family members in a criminal case arising out of a matrimonial dispute, without specific allegations indicating their active involvement should be nipped in the bud.” The Court noted that such practices created “significant divisions and distrust among people” and imposed unnecessary strain on the judicial system.

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The Court recorded: “In the aforementioned facts of the case and keeping the judicial dicta rendered by this Court in mind, we find that the impugned order dated 27.02.2024 of the High Court ought to be set aside and is set aside.” It directed that FIR No.347 of 2023 dated 09.11.2023 registered at Police Station Civil Lines, Meerut, and all consequent proceedings pursuant thereto, stand quashed only with respect to the appellant.

“It is needless to observe that the observations made in the present appeal shall not come in the way of any other proceedings pending between the parties which shall be decided on their own merits and in accordance with law.” Accordingly, the appeal was allowed.

Advocates Representing the Parties

For the petitioner(s): Mr. Saurabh Soni, Advocate, Mr. Maneesh Saxena, Advocate, Mr. Anupam Singh, AOR, and Ms. Mannat Singh, Advocate.

For the respondent(s): Dr. Vijendra Singh, AOR, Mr. Vikas Bansal, Advocate, Ms. Apurva Singh, Advocate, Mr. Devesh Kumar Mishra, AOR, and Mr. Vasasntha Kumar, Advocate.

Case Title: Shobhit Kumar Mittal v. State of Uttar Pradesh & Another
Neutral Citation: 2025 INSC 1152
Case Number: Criminal Appeal No. of 2025 (arising out of SLP (Criminal) No.4069 of 2024)
Bench: Justice B.V. Nagarathna, Justice R. Mahadevan