In a pivotal judgment, the Supreme Court of India underscored the scope of Section 482 of the Code of Criminal Procedure (Cr.P.C.), emphasizing that petitions seeking the quashing of chargesheets can be filed even before the framing of charges. This decision, rendered in the context of a contentious matrimonial dispute, has significant implications for cases involving alleged misuse of criminal provisions such as dowry harassment and cheating.
The bench, comprising Justice C.T. Ravikumar and Justice Rajesh Bindal, delivered the ruling while adjudicating cross-appeals arising from the Punjab and Haryana High Court’s decision on two connected cases.
Background of the Case
The case revolved around a matrimonial dispute that quickly escalated into criminal allegations. A marriage solemnized in early 2019 deteriorated within months, with the couple relocating to Canada separately. Following the breakdown of the marriage and divorce proceedings initiated abroad, the complainant—parent of one of the parties—filed a police complaint in late 2020, alleging harassment and dowry demands against the spouse and six of their relatives.
The accused included:
- Husband (Accused No. 1)
- A cousin (Accused No. 6)
- The cousin’s spouse (Accused No. 5)
The complaint alleged offenses under Sections 406 (criminal breach of trust), 498-A (cruelty by husband or relatives), 420 (cheating), and 120-B (criminal conspiracy) of the Indian Penal Code.
Punjab and Haryana High Court’s Decision
Two of the relatives filed a joint petition under Section 482 Cr.P.C. before the High Court to quash the FIR, arguing that the allegations were baseless and exaggerated.
The High Court:
- Quashed the FIR against the cousin (Accused No. 6), citing the absence of specific allegations.
- Refused to quash the FIR against the cousin’s spouse (Accused No. 5), citing “specific allegations” that warranted trial.
This led to cross-appeals in the Supreme Court by the relative whose petition was rejected and the complainant, who sought reinstatement of the FIR against the cousin.
Legal Issues Before the Supreme Court
- Scope of Section 482 Cr.P.C.:
Whether the High Court’s inherent powers under Section 482 could be invoked to quash a chargesheet or FIR before the framing of charges. - Over-implication in Matrimonial Disputes:
Whether vague and generalized allegations against distant relatives should result in criminal proceedings. - Proof of Active Involvement:
Whether mere familial connections or geographic proximity justify implicating individuals in matrimonial disputes. - Abuse of Process of Law:
Whether the FIR was being used as a tool to pressurize the main accused or their relatives.
Supreme Court’s Observations and Ruling
1. Quashing of Chargesheet Before Framing of Charges
The Court reaffirmed that Section 482 Cr.P.C. empowers courts to quash proceedings at any stage, even before charges are framed. It emphasized that technicalities must not deter courts from exercising these powers to prevent harassment and protect justice.
Quoting Umesh Kumar v. State of Andhra Pradesh, the Court noted: “It would not be in the interest of justice to reject an application under Section 482 merely because the chargesheet has been filed. If allegations are baseless or improbable, courts should not hesitate to intervene.”
2. Over-implication in Matrimonial Disputes
The Court highlighted the increasing misuse of criminal law in matrimonial disputes, where distant relatives are often roped in with exaggerated allegations. Referring to its earlier rulings in Preeti Gupta v. State of Jharkhand and Geeta Mehrotra v. State of U.P., the bench observed: “Courts must exercise caution and examine allegations critically, especially against relatives who live separately and have minimal interaction with the complainant.”
In this case, the Court found that the accused relatives lived in a different city, far from the complainant and the alleged victim. There were no allegations of direct involvement or specific acts attributable to them.
3. Vague Allegations Against the Relative (Accused No. 5)
The Court noted that the allegations against this relative were “omnibus and vague,” lacking any substantive evidence. The FIR merely mentioned the person as a relative without detailing their role in the alleged harassment or demands. The Court observed: “It is not sufficient to make sweeping accusations against relatives in matrimonial disputes. Specific instances of cruelty or involvement must be clearly established.”
Consequently, the Court quashed the FIR and subsequent proceedings against the accused.
4. Appeal Against Relief Granted to Another Relative (Accused No. 6)
The complainant argued that the High Court erred in quashing the FIR against the other accused relative. However, the Supreme Court upheld the High Court’s decision, noting that no allegations were made against this person that could constitute offenses under Sections 406, 498-A, or 420 IPC. The bench observed: “When allegations fail to meet the threshold of criminal liability, allowing such cases to proceed would amount to an abuse of judicial process.”
