25 June 2025 Evidence >> Criminal Law  

In a significant ruling of Kaushalya Bai & Others v/s The State Of Madhya Pradesh, the High Court has quashed an FIR (First Information Report) and all subsequent proceedings related to Crime No. 493 of 2023, registered at Police Station Kurawar (Kotara), District Rajgadh. The case involved allegations under Sections 306 (abetment of suicide), 498-A (cruelty by husband or relatives of husband), and 34 (common intention) of the Indian Penal Code (IPC). The petitioners, who were the family members of the deceased woman's husband, had sought to quash the FIR, arguing that the allegations did not constitute the alleged offenses.

The case originated from the death of Mamtabai, who was found to have died by hanging on August 21, 2023. While the initial medical opinion suggested asphyxia, with the possibility of strangulation not being ruled out, subsequent forensic analysis found no poisonous substances, and DNA profiling from the deceased's underwear did not match the blood samples of the male relatives. A later opinion from the medical experts definitively concluded that Mamtabai's death was suicidal due to mechanical obstruction.

 

 

The FIR was registered based on statements from Mamtabai's maternal relatives, who alleged that her husband's family had been harassing her over domestic issues, particularly after her husband, Ramniwas, died five years prior. They also claimed that Bhagwat Prasad, a brother-in-law, wanted to transfer Mamtabai's land to himself. A past scuffle involving Rajkumar, another brother-in-law, was also mentioned, though it occurred almost three years before Mamtabai's death.

The petitioners' counsel argued that the allegations, even if taken at face value, did not meet the legal requirements for offenses under Sections 306 and 498-A IPC. They cited several Supreme Court judgments, including Chitresh Kumar Chopra v. State (Govt of NCT of Delhi) and Gangula Mohan Reddy v. State of AP, to emphasize that for abetment of suicide, there must be a clear mens rea (guilty mind) and a direct or active act of instigation in close proximity to the suicide. Mere harassment or scolding over domestic work, especially if not immediately preceding the death, would not constitute abetment.

Regarding Section 498-A IPC, the petitioners' counsel highlighted the Supreme Court's observations in Dara Lakshmi Narayana v. State of Telangana and Preeti Gupta v. State of Jharkhand, which caution against the misuse of this provision and the tendency to implicate all family members without specific, concrete allegations. These judgments emphasize the need for courts to scrutinize generalized accusations to prevent the harassment of innocent family members.

After reviewing the facts and legal precedents, the High Court concluded that the prosecution's case lacked the essential ingredients to establish offenses under Sections 306 and 498-A IPC. The court noted:

• No Proximate Link for Abetment: There was no "positive or direct allegation" that the petitioners "intended the death of Mamtabai or they had goaded, urged, provoked, incited or encouraged Mamtabai to commit suicide." The alleged scuffle was a stale incident, and general allegations of harassment over domestic work did not establish the necessary "live link" or "proximate" action compelling the deceased to commit suicide.
• Vague Allegations of Cruelty: The allegations of harassment under Section 498-A IPC were found to be "general and omnibus in nature, bereft of specific details and particular incidents."

Citing the principles laid down in State of Haryana v. Ch. Bhajan Lal, the High Court found that the allegations, even if accepted, did not prima facie constitute the offenses. The court held that allowing further proceedings would be a "futile exercise" and an "abuse of the process of law," causing "severe prejudice" to the petitioners.

Consequently, the High Court exercised its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, and quashed the FIR and all consequential proceedings against the petitioners, bringing an end to the ongoing legal battle.

Indian Penal Code, 1860  

BHARATIYA NAGARIK SURAKSHA SANHITA, 2023