The Supreme Court dismissed a Special Leave Petition challenging the Allahabad High Court’s order that quashed criminal proceedings against the petitioner’s husband and in-laws. The Court found the allegations to be vague, inconsistent, and lacking sufficient material to justify prosecution, and affirmed the High Court’s invocation of powers under Section 482 of the Criminal Procedure Code (CrPC) to prevent abuse of the process of law.
Background
The petitioner had initiated proceedings under Section 156(3) CrPC, alleging offences under Sections 498A (cruelty), 325 (grievous hurt), and 506 (criminal intimidation) of the Indian Penal Code, 1860, along with Sections 3 and 4 of the Dowry Prohibition Act, 1961. The complaint, filed before the Additional Chief Judicial Magistrate, Lucknow, named ten members of the husband’s family, including his parents, paternal uncles, their wives, and children.
On 8 November 2023, the Magistrate summoned only the husband and his parents, rejecting allegations against the extended family due to inconsistencies noted between the complaint and the statements recorded under Sections 200 and 202 CrPC. The Magistrate relied on the judgment in Geeta Mehrotra v. State of U.P., (2012) 10 SCC 741.
Subsequently, the husband and his parents approached the Allahabad High Court, which quashed the proceedings in their entirety under Section 482 CrPC, citing the judgment in Preeti Gupta v. State of Jharkhand, (2010) 7 SCC 667. The High Court emphasised the need for courts to exercise caution in matrimonial disputes where extended family members are routinely implicated without sufficient basis.
Court Proceedings
The bench comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran heard submissions from both sides.
The Supreme Court declined to delve into facts related to pending matrimonial proceedings under the Hindu Marriage Act, noting that an appeal from the Family Court’s judgment was still sub judice. The Court instead confined itself to the veracity of the criminal complaint.
It observed several discrepancies in the petitioner’s version of events. While she alleged she was thrown out of her matrimonial home on 28 September 2020, she also claimed cordial relations continued afterward, including receiving a cheque of ₹50,000 from her husband on 26 October 2020 for festive purchases.
The Court noted, “The petitioner had taken contrary stands and there are inconsistencies in the complaint and statement which was made before the Magistrate, which persuade us to find the proceedings to be a clear abuse of process of the Court.”
Further, the bench found no substantiating evidence such as medical records for the alleged fracture and physical assault. It also highlighted that the petitioner’s affidavit in Family Court proceedings admitted cordial relations during the period when she now alleged harassment.
Decision
Upholding the High Court’s decision, the Supreme Court ruled that the quashing of proceedings under Section 482 CrPC was justified. It found no reason to interfere, holding that the criminal case was “a clear abuse of process of law” and the High Court’s exercise of jurisdiction had secured the ends of justice.
The Special Leave Petition was dismissed, and all pending applications were disposed of.
