Supreme Court Quashes Dowry and Cyber Offence FIR After Couple Marries, Emphasizes Amicable Resolution Over Prosecution.


12 November 2025 Criminal Appeals & Suspension of Sentence >> Criminal Law   |   FIR >> Criminal Law   |   Dowry >> Marriage Law  

In a recent order, the Supreme Court of India brought a peaceful closure to a criminal case arising out of a matrimonial dispute by quashing an FIR lodged under provisions of the Bharatiya Nyaya Sanhita, 2023 (BNS), the Dowry Prohibition Act, 1961, and the Information Technology Act, 2000. A Bench comprising Justice B.V. Nagarathna and Justice R. Mahadevan allowed the appeal filed by accused Gourav Pathak against the order of the Allahabad High Court that had earlier refused him anticipatory bail.

The case originated with an FIR lodged on 7 June 2025 at Police Station Indirapuram, Ghaziabad, under Section 69 of the BNS, Sections 3 and 4 of the Dowry Prohibition Act, and Section 67A of the IT Act, against the appellant by the woman who was then in a relationship with him. She accused him and his family of dowry-related harassment and circulation of objectionable material online, thereby invoking both penal and cyber law provisions.

 

 

After registration of the FIR, the appellant filed an application before the High Court for anticipatory bail under Section 482 of the BNSS. The same was rejected vide order dated 6 August 2025. Aggrieved by the said order, the appellant approached this court. An interim order was passed on 1 September 2025 granting protection from arrest to the petitioner.

Subsequently, a major development took place-which was that on 6 September 2025, the appellant and the complainant got married. A joint application was filed before the Supreme Court by the couple to seek quashing of the FIR, citing that all differences had been sorted out and they were living together as husband and wife at Bengaluru.

The Bench, thus, noted that the developments in the case indicate that the original complaint was based on apprehensions and misunderstandings in the course of a love relationship, as the complainant might have perceived that the appellant would not marry her. Once the marriage was solemnized, the allegations in furtherance of which the charge-sheet was filed lost their relevance. The State’s counsel, too, did not oppose the plea for quashing in view of the changed circumstances.

The Court, therefore, set aside the High Court's order refusing anticipatory bail, granted protection to the appellant, and quashed the FIR along with all the proceedings connected with it. It held that the criminal allegations no longer survived in view of the amicable settlement between the parties.

This order is a reflection of the judiciary’s pragmatic approach when dealing with interpersonal disputes that culminate in criminal litigation, especially in cases arising from failed or strained relationships.

The intervention by the Supreme Court underlines the fact that the object of criminal law is not punitive alone but restorative in nature, where continuation of proceedings serves no meaningful purpose once the parties have reconciled.

Furthermore, the judgment carries wider ramifications under the newly enacted BNS and BNSS framework. It shows how settled principles under the pre-2023 criminal laws continue to operate: that in personal or matrimonial disputes where parties have settled differences, the Court can invoke its inherent powers to prevent the abuse of the process of law and secure the ends of justice.


Section 69, BHARATIYA NYAYA SANHITA - 2023  

BHARATIYA NYAYA SANHITA, 2023  

Section 3, Dowry Prohibition Act - 1961  

Section 4, Dowry Prohibition Act - 1961  

Dowry Prohibition Act, 1961  

Section 67, Information Technology Act - 2000  

Information Technology Act, 2000  

Section 482, BHARATIYA NAGARIK SURAKSHA SANHITA - 2023  

BHARATIYA NAGARIK SURAKSHA SANHITA, 2023