Quashing of Dowry Harassment Case Against Distant Relatives Based on Omnibus Allegations.
23 April 2025
Criminal Appeals & Suspension of Sentence >> Criminal Law | Dowry >> Marriage Law
In Muppidi Lakshmi Narayana Reddy & Others v/s The State of Andhra Pradesh & Another., the appellants (sister-in-law, brother-in-law, and father-in-law of the husband) challenged a High Court order that dismissed their petition to quash proceedings against them in a dowry case (C.C. No. 359 of 2016). The case arose from a matrimonial dispute between the de-facto complainant (wife) and her husband (A1). The appellants, residing in Hyderabad, were accused of visiting the marital home in Guntur and instigating the husband and his parents to demand dowry. The complaint included general allegations of taunting and claiming political influence.
The Supreme Court, relying on its previous judgments in Geeta Mehrotra and Dara Lakshmi Narayana, noted the growing trend of implicating all relatives in dowry cases with omnibus and unspecific allegations. The Court emphasized that the appellants lived in Hyderabad, while the complainant resided in Guntur. Finding no specific dates or instances of their alleged involvement and noting the absence of physical torture allegations against them, the Supreme Court held that the criminal case against the appellants was an abuse of the legal process. The Court quashed the proceedings against the appellants, allowing their appeal.