The Supreme Court has quashed criminal proceedings against the parents-in-law of a complainant, observing that the allegations leveled against them were “vague and omnibus” and lacked specific instances of cruelty or dowry demands.
The Bench, comprising Justice B.V. Nagarathna and Justice R. Mahadevan, allowed the appeal filed by the parents-in-law, setting aside the order of the High Court for the State of Telangana which had declined to quash the proceedings.
Background of the Case
The case arose from a matrimonial dispute between the complainant (Respondent No. 2) and her husband, the son of the appellants. The couple was married on August 12, 2012, and a daughter was born to them on November 1, 2013.
On March 4, 2023, nearly a decade after the marriage, Respondent No. 2 filed a complaint with the SHO, Women Police Station, Nalgonda. She alleged that at the time of marriage, her family had given Rupees Four Lakhs Fifty Thousand in cash, 90 grams of gold, and domestic utensils. She stated that while they lived happily for eight years, her husband’s conduct changed after the birth of their daughter.
The complainant alleged that her husband, “influenced by the words of the appellant(s), sister-in-law and sister-in-law’s husband,” began abusing her in vulgar language and beating her, demanding an additional dowry of Rupees Four Lakhs. Following the complaint, an FIR (No. 28/2023) was registered against six accused persons, including the appellants, for offences punishable under Sections 498A (cruelty), 323 (voluntarily causing hurt), 504 (intentional insult) read with Section 34 of the Indian Penal Code (IPC), and Section 4 of the Dowry Prohibition Act, 1961.
Subsequently, a chargesheet was filed, and the Special Judicial First Class Magistrate at Nalgonda took cognizance of the offences. The appellants approached the High Court of Telangana under Section 482 of the Code of Criminal Procedure (CrPC) seeking to quash the proceedings. However, by an order dated February 20, 2025, the High Court disposed of the petition, reserving liberty for them to apply for discharge before the trial court. Aggrieved by this, the appellants approached the Supreme Court.
Arguments and Observations
The appellants contended that the allegations against them were baseless. Despite notice being served on June 10, 2025, Respondent No. 2 did not appear before the Supreme Court.
Upon reviewing the material, the Supreme Court observed that the allegations in the FIR were “vague and omnibus.” The Court noted the “absence of any specific instance or occasion detailed with particulars wherein the appellant(s) demanded dowry from Respondent No. 2 and on refusal of the same, subjected her to mental and physical cruelty.”
The Bench found that the primary allegation was that the husband’s conduct underwent a change due to the “alleged inducement exercised by the in-laws including the appellant(s) herein.” The Court stated:
“We therefore find that the aforesaid allegations levelled against the appellant(s), even if taken at their face value, do not prima facie disclose the commission of the alleged offences so as to warrant the initiation of criminal proceedings.”
Court’s Analysis and Reliance on Precedent
The Court relied heavily on its recent judgment in Dara Lakshmi Narayana vs. State of Telangana, (2025) 3 SCC 735, delivered by Justice B.V. Nagarathna. The Bench quoted the following observation from that judgment:
“A mere reference to the names of family members in a criminal case arising out of a matrimonial dispute, without specific allegations indicating their active involvement should be nipped in the bud. It is a well-recognised fact, borne out of judicial experience, that there is often a tendency to implicate all the members of the husband’s family when domestic disputes arise out of a matrimonial discord.”
The Court further reiterated that generalized and sweeping accusations unsupported by concrete evidence cannot form the basis for criminal prosecution. Citing Dara Lakshmi Narayana, the judgment highlighted the misuse of Section 498A IPC:
“However, in recent years, as there have been a notable rise in matrimonial disputes across the country… there has been a growing tendency to misuse provisions like Section 498-A IPC as a tool for unleashing personal vendetta against the husband and his family by a wife.”
Decision
Applying the principles laid down in Dara Lakshmi Narayana, the Supreme Court held that the High Court erred in not exercising its powers to prevent the abuse of the process of law.
The Court ordered:
“The proceedings instituted against the appellant(s) in C.C. No.338/2023 pending on the file of the Judicial First Class Magistrate (Prohibition and Excise offence) at Nalgonda stand quashed in relation to the appellants herein.”
The appeal was allowed.
Case Details:
- Case Title: Maram Nirmala & Anr. Versus The State of Telangana & Anr.
- Case Number: Criminal Appeal No. of 2025 (Arising out of SLP (Crl.) No. 7597/2025)
- Citation: 2025 INSC 1496
- Coram: Justice B.V. Nagarathna and Justice R. Mahadevan
