Kiran Raj

The Supreme Court of India, Division Bench of Justices Sanjay Karol and Prashant Kumar Mishra set aside the Madhya Pradesh High Court’s Indore Bench order that had quashed an FIR registered under Section 498A of the Indian Penal Code and provisions of the Dowry Prohibition Act, 1961, filed by a woman against her husband and his relatives. The Court held that the High Court exceeded its jurisdiction by assessing the truthfulness of the allegations and effectively conducting a ‘mini-trial’ at the stage of quashing. Observing that the complaint and FIR contained prima facie material indicating cruelty and dowry demands, the Supreme Court restored the criminal proceedings and directed that the trial continue in accordance with law.

The case arose from a criminal appeal filed by a woman challenging an order of the Madhya Pradesh High Court at Indore, which had quashed criminal proceedings arising from an FIR registered under Section 498A of the Indian Penal Code, 1860 and Sections 3 and 4 of the Dowry Prohibition Act, 1961. The FIR alleged cruelty and harassment by her husband and his family members after five to six months of marriage, citing demands for dowry and verbal abuse. The complainant stated that she was asked to bring Rs. 50 lakhs from her father to enable her husband to pursue a medical examination and was expelled from her matrimonial home along with her son. Prior to the FIR dated 28 January 2024, she had lodged complaints before the Women’s Cell, Ratlam, on 22 and 23 January 2023, alleging consistent harassment and dowry demands.

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The private respondents filed a petition under Section 482 of the Code of Criminal Procedure seeking quashing of the FIR, contending that the allegations were inconsistent and lacked specific details, pointing to delays in filing the FIR and vague, omnibus charges against certain family members. The State opposed the petition, arguing that quashing should only be used sparingly and that the High Court should not assess the veracity of the allegations at that stage. The High Court, however, quashed the FIR, concluding that the allegations of harassment on 22 July 2021 and 27 November 2022 appeared to be afterthoughts. The woman appealed to the Supreme Court, which heard arguments from her counsel, the Amicus Curiae representing unrepresented respondents, and the State of Madhya Pradesh.

The Court observed: “The main issue that arises for our analysis is whether the High Court was right in quashing the criminal proceedings against the private respondents primarily on the ground that the earlier complaints did not mention the two specific incidents dated 22.07.2021 and 27.11.2022, which were later on added in the FIR and whether the same would not amount to conducting a ‘mini trial’ which is clearly prohibited under the scheme of Section 482 of the Cr.PC.”

The Bench stated: “From a bare perusal of the above mentioned paragraphs it can be seen that one of the important factors that weighed in while allowing the quashing application of the private respondents was that in the earlier complaints filed by the appellant, there was no mention of the events of harassment that happened on 22.07.2021 and 27.11.2022, which were later on added in the FIR dated 28.01.2024.”

The Court recorded: “It is settled that at the stage of quashing, the Court is not required to conduct a mini trial. Thus, the jurisdiction under Section 482 of the Cr.PC with respect to quashing is somewhat limited as the Court has to only consider whether any sufficient material is available to proceed against the accused or not. If sufficient material is available, the power under Section 482 should not be exercised.”

Referring to precedents, the Court stated: “The power of quashing should be exercised sparingly and with circumspection and in rare cases. As per the settled proposition of law while examining an FIR/complaint quashing of which is sought, the court cannot embark upon any enquiry as to the reliability or genuineness of allegations made in the FIR/complaint.”

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The Court further noted: “We are of the view that the High Court has erred in law by embarking upon an enquiry with regard to credibility or otherwise of the allegations in the complaints and the FIR… This approach adopted by the High Court, in our considered opinion, amounts to conducting a mini trial.”

The Court stated: “Accordingly, in our view, the present case warrants interference by this Court, and we do so. We hereby set aside the impugned order passed by the High Court in Miscellaneous Criminal Case No.10695 of 2024.”

“The Appeal is, accordingly, allowed. All contentions and defences available to the respective parties are kept open which shall be considered by the Trial Court on its own merits and in accordance with law.”

Advocates Representing the Parties

For the Petitioner: Mr. Pavani Verma, Adv. Mr. Mayank Kshirsagar, AOR
For the Respondents: Mr. Aditya Vaibhav Singh, Adv. Mr. Pashupathi Nath Razdan, AOR Ms. Maitreyee Jagat Joshi, Adv. Mr. Gautam Singh, Adv. Mr. Astik Gupta, Adv. Ms. Akanksha Tomar, Adv. Mr. Yaduven, Adv.

Case Title: Muskan v. Ishaan Khan (Sataniya) and Others
Neutral Citation: 2025 INSC 1287
Case Number: Criminal Appeal No. 4752 of 2025 (arising out of SLP (Crl.) No. 1531 of 2025)
Bench: Justice Sanjay Karol, Justice Prashant Kumar Mishra