The Supreme Court of India, in a judgment delivered on November 6, 2025, ruled that a High Court, exercising its powers under Section 482 of the Code of Criminal Procedure (Cr.PC), cannot conduct a “mini trial” or assess the credibility of allegations to quash a First Information Report (FIR).
The apex court bench, comprising Justice Sanjay Karol and Justice Prashant Kumar Mishra, set aside an order from the High Court of Madhya Pradesh which had quashed an FIR filed under Section 498A of the Indian Penal Code (IPC) and Sections 3 and 4 of the Dowry Prohibition Act, 1961. The Supreme Court held that the High Court erred in quashing the proceedings on the ground that certain specific incidents mentioned in the FIR were absent from earlier complaints.
The judgment was delivered in Criminal Appeal No. 4752 of 2025.
Background of the Case
The appellant-wife and respondent No. 1, the husband, were married on November 20, 2020, and had a son. According to the facts recorded, the appellant alleged that after 5-6 months of marriage, she was harassed by her husband and his family members for dowry.
On January 28, 2024, the appellant registered FIR No. 35 of 2024 at Police Station Alot, District Ratlam, against her husband (respondent No. 1), mother-in-law (respondent No. 2), father-in-law (respondent No. 3), sister-in-law (respondent No. 4), and brother-in-law (respondent No. 5).
The FIR detailed allegations of taunts for insufficient dowry. It specifically mentioned two incidents:
- On July 22, 2021, all five respondents allegedly hurled abuses at her, and her brother-in-law (respondent No. 5) slapped her, asking her to bring dowry.
- On November 27, 2022, her husband (respondent No. 1) allegedly demanded Rs. 50 lakhs to pursue an MIC examination, stating he would only keep her if the demand was met. Following this, he allegedly ousted her and their son from the matrimonial home.
The appellant stated that her father’s attempts at reconciliation failed as the respondents were “adamant in their demand for the sum of Rs. 50 lakhs.”
The private respondents subsequently filed Miscellaneous Criminal Case No. 10695 of 2024 under Section 482 Cr.PC before the High Court of Madhya Pradesh at Indore, seeking to quash the FIR. On July 19, 2024, the High Court allowed the petition and quashed the criminal proceedings, prompting the appellant to appeal to the Supreme Court.
Arguments Before the Supreme Court
The Supreme Court appointed a learned Amicus Curiae for the unrepresented private respondents.
Counsel for Respondent No. 6 (State of Madhya Pradesh): The State argued that the power of quashing should be exercised only in the “rarest of rare cases.” It was submitted that a court examining an FIR “ought not to embark upon an enquiry as to the reliability and genuineness of allegations.” The counsel contended that the omission of the two specific incidents from earlier complaints (dated 22.01.2023 and 23.01.2023) could not be termed an “afterthought” when other specific allegations of harassment and dowry demand were present. Reliance was placed on Neeharika Infrastructure Private Limited v. State of Maharashtra and Others and State of Haryana and Others v. Bhajan Lal and Others.
Learned Amicus Curiae (for Respondent Nos. 1-5): The Amicus Curiae submitted that the earlier complaints lodged by the appellant before the Women’s Cell in Ratlam were “generic in nature” and did not mention the specific dates of 22.07.2021 and 27.11.2022, nor the “crystallized amount” of Rs. 50 lakhs. It was argued that the FIR was lodged after a delay of one year from the earlier complaints and that the allegations against respondents 2 to 4 were “vague and omnibus.”
Supreme Court’s Analysis and Decision
The Supreme Court identified the core issue as whether the High Court was right to quash the FIR “primarily on the ground that the earlier complaints did not mention the two specific incidents… and whether the same would not amount to conducting a ‘mini trial'”.
The Court, in its judgment authored by Justice Prashant Kumar Mishra, noted that the High Court’s decision was significantly influenced by this omission. The High Court had concluded in its order that the incidents of 22.07.2021 and 27.11.2022 were an “afterthought” and a “counterblast” to a notice sent by the husband.
However, the Supreme Court, after extracting the contents of the earlier complaints dated 22.01.2023 and 23.01.2023, found that they did contain “prime facie allegations of harassment and demand of dowry against the private respondents.” These included demands for a car and an A.C., restrictions on food, and threats from the in-laws.
The apex court reiterated the settled legal position on the limited scope of Section 482 Cr.PC. Citing State of Odisha v. Pratima Mohanty and Others and Central Bureau of Investigation v. Aryan Singh and Others, the bench emphasized that at the stage of quashing, “the Court is not required to conduct a mini trial.”
Quoting the 2021 decision in Neeharika Infrastructure, the Court stated: “33.5. While examining an FIR/complaint, quashing of which is sought, the court cannot embark upon an enquiry as to the reliability or genuineness or otherwise of the allegations made in the FIR/complaint.”
The Supreme Court found that the High Court had erred in its approach. “We are of the view that the High Court has erred in law by embarking upon an enquiry with regard to credibility or otherwise of the allegations in the complaints and the FIR,” the judgment stated.
The Court held that a “conjoint reading of the complaints and the FIR” showed that “prime facie allegations of harassment and demand of dowry are made out.”
Concluding that the High Court’s approach “amounts to conducting a mini trial,” the Supreme Court allowed the appeal and set aside the impugned order.
“Accordingly, in our view, the present case warrants interference by this Court, and we do so. We hereby set aside the impugned order passed by the High Court in Miscellaneous Criminal Case No.10695 of 2024,” the Court directed.
The criminal proceedings emanating from FIR No. 35 of 2024 are restored. The Supreme Court clarified that all contentions and defences available to the respective parties are “kept open which shall be considered by the Trial Court on its own merits and in accordance with law.”
case Title: Muskan v. Ishaan Khan (Sataniya) and Others
Criminal Appeal No. 4752 of 2025
