Supreme Court Quashes Dowry Case Against Father-in-Law After Divorce.


12-August-2025 Criminal Appeals & Suspension of Sentence >> Criminal Law  

The Supreme Court of India has quashed criminal proceedings against a man accused by his daughter-in-law of cruelty and dowry demands. The case of Mange Ram v/s State of Madhya Pradesh involved the appellant (father-in-law) and his son, who were accused by the son's ex-wife of offenses under Section 498A of the Indian Penal Code and the Dowry Prohibition Act.

The marriage, solemnized in 2017, began to unravel by 2019. The couple sought counseling, but reconciliation failed, leading the wife to file a First Information Report (FIR) on July 21, 2019. She accused her husband and his family, including the appellant, of demanding dowry and physical and mental cruelty. A specific allegation against the father-in-law was that he had slapped her at a railway station and demanded a large sum of money.


 

 

The High Court had previously quashed the proceedings against the mother-in-law and sister-in-law, citing a lack of specific allegations, but it refused to do so for the father-in-law and the husband, noting specific accusations against them.

The Supreme Court, however, found several key issues with the case against the father-in-law. It noted that the FIR was filed almost two months after the alleged incident at the railway station and after the husband had initiated divorce proceedings. The court found it suspicious that these serious allegations were not raised during the prior police counseling sessions.

Crucially, the Court considered that the couple's marriage had been legally dissolved by a divorce decree in August 2021. Citing past precedents, the court emphasized that continuing criminal proceedings against family members after a divorce, especially when the allegations lack a clear, timely basis, serves no useful purpose. The court highlighted a "recurring tendency to implicate every member of the husband's family" and stated that criminal law should not be used as an instrument of harassment.

Ultimately, the Supreme Court exercised its power under Article 142 of the Constitution of India to "do complete justice" and quashed the FIR and all related criminal proceedings against the appellant (the father-in-law), concluding that further prosecution would only prolong bitterness and amount to an abuse of the legal process.


Section 498A., Indian Penal Code - 1860  

Indian Penal Code, 1860  

Dowry Prohibition Act, 1961  

Section 142, Constitution of India - 1950  

Constitution of India, 1950