The Supreme Court of India, in Rohan & Ors. vs State of Gujarat & Anr., quashed a criminal proceeding initiated by the wife against her husband and in-laws, citing the allegations as frivolous and an abuse of the legal process. The bench comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran found no material evidence supporting deception regarding the husband’s skin condition or professional qualifications.
Background:
The case arose from a complaint lodged by the wife (Respondent No. 2) against her husband (Appellant No. 1) and his family. The marriage took place on 10 April 2023, and the couple lived together for approximately four months. On 30 September 2023, the wife filed an FIR alleging that she was misled into marrying the husband based on false representations — primarily that he was an Eye Surgeon when he was, in fact, an Optometrist, and that his skin condition (leukoderma) was concealed from her.
Arguments and High Court Proceedings:
The appellants approached the Gujarat High Court under Section 482 CrPC seeking quashing of the FIR. However, the High Court dismissed their petition by an order dated 22 July 2024, prompting the appeal to the Supreme Court.
Supreme Court’s Analysis:
The Court examined the material on record, including WhatsApp chats between the parties, and concluded:
“From all reasonable assumptions as well as the documents which have been placed before us, it is clear that the complainant had full knowledge that the appellant was suffering from skin disease and he was not an Eye Surgeon, but an Optometrist.”
It was further observed that there was no effort on the part of the appellant to deceive or mislead the complainant. The Court also noted that the complainant, at the time of the marriage, was an M.Com student and had married against her parents’ wishes.
Labeling the FIR as motivated by “extraneous reasons”, the Court held:
“This is a befitting case where the High Court should have exercised its powers under Section 482 of the Criminal Procedure Code and should have quashed the proceedings as this is nothing but an abuse of process of law.”
Decision:
The Supreme Court allowed the appeal, set aside the Gujarat High Court’s judgment, and quashed the criminal proceedings initiated against the appellants. The order concluded with the following direction:
“Thus, for the reasons stated above, we quash the criminal proceedings against the appellant(s) and set aside the impugned order passed by the High Court. The appeal stands allowed.”
