Supreme Court Quashes FIR Against In-Laws in Dowry and Cruelty Case, Proceedings to Continue Against Husband.
26 September 2025
Criminal Appeals & Suspension of Sentence >> Criminal Law
The Supreme Court has reserved criminal trials against a complainant's father-in-law, mother-in-law, and sister-in-law who were accused of cruelty and dowry harassment under Section 498-A of the Indian Penal Code (IPC), reserving while making it clear that the trial against the complainant's husband on similar charges, including those under Sections 377 and 506 IPC, will proceed.
Background of the Case:
The complainant got married to Piyush, son of appellant Nos. 1 and 2 and brother of appellant No. 3, on July 14, 2021. She complained that her husband's family kept insisting on dowry and other gifts from time to time even after the marriage. In her version, when she went to her parent's house in August 2021, she was once again requested to bring clothes and jewellery, which she tried to fulfill on return. She also alleged that her husband coerced her into unnatural sexual acts, resulting in mental trauma for her.
On the basis of these charges, FIR No. 20 of 2022 was lodged at the Bajaj Nagar Police Station, Nagpur, under Section 498-A IPC initially. Section 377 and 506 were subsequently added. The final report also charged the husband and his kin.
The husband, together with the in-laws, had sought quashing of proceedings before the Bombay High Court's Nagpur Bench under Section 482 of the Code of Criminal Procedure. The High Court refused and held that there was prima facie material for trial. The husband did not appeal against this order any further, but the appellants (in-laws) went to the Supreme Court.
Arguments Before the Court:
The appellants moved that the FIR did not contain specific allegations against them that would amount to offences under Sections 498-A, 377, or 506 read with Section 34 IPC. They contended that the complaint contained vague and general averments without particulars and that proceeding further would amount to abuse of process.
The State of Maharashtra and the aggrieved person resisted the plea stating that the FIR contained uniform demands for dowry, and material facts could emerge during trial.
Supreme Court's Findings:
On consideration of the FIR and final report, the Bench observed that the majority of allegations against the in-laws were sweeping in nature and lacked specifics. Except for one observation about a demand for clothes and jewellery, other mentions were omnibus in nature. The Court laid special stress that for an offence under Section 498-A, allegations need to reveal cruelty of the kind likely to drive the victim to suicide or grievous hurt, or harassment for compliance with specific unlawful demands for property or valuables. No such allegations were made against the appellants.
As far as Sections 377 and 506 IPC are concerned, the Court noted that all charges of unnatural sex and threat were made only against the husband of the complainant, not against his relatives.
Relying on the principles enunciated in State of Haryana vs. Bhajan Lal (1990), the Court held that proceeding against the appellants would be abuse of process.
Decision:
The Supreme Court quashed FIR No. 20 of 2022 and proceedings thereunder insofar as they pertained to the appellants. It made it clear, however, that this does not impinge on the prosecution of the complainant's husband, against whom proceedings will proceed on their own merit.
The in-laws' appeal was accordingly granted, with no order as to costs.
Section 377., Indian Penal Code - 1860
Section 498A., Indian Penal Code - 1860
Section 506., Indian Penal Code - 1860