The Supreme Court of India, in a significant ruling, has quashed criminal proceedings against a man, observing that vague and omnibus allegations of dowry harassment are insufficient to sustain a case under Section 498A of the Indian Penal Code. A bench comprising Justice B.V. Nagarathna and Justice R. Mahadevan set aside an order by the Allahabad High Court, which had refused to quash an FIR against the appellant. The Court held that allowing the prosecution to continue based on such general allegations would be an abuse of the process of law.
Background of the Case
The matter originated from a matrimonial dispute. The complainant married the appellant’s brother on May 1, 2014. Due to marital discord, she left her matrimonial home a few months after the marriage.
On November 9, 2023, the complainant lodged an FIR at Police Station Civil Lines, Meerut, against her husband, her mother-in-law, and her brother-in-law (the appellant). The FIR invoked Sections 323 (punishment for voluntarily causing hurt) and 498A (husband or relative of husband of a woman subjecting her to cruelty) of the Indian Penal Code, 1860, along with Sections 3 and 4 of the Dowry Prohibition Act, 1961.
The FIR contained three primary allegations:
- The complainant faced harassment for dowry within ten days of her marriage.
- The appellant, along with the husband and mother-in-law, had her write a consent letter, which was also signed by her relatives, to allow her to live at her matrimonial home.
- On December 10, 2022, due to repeated dowry-related harassment, a vein in her brain burst, leading to the paralysis of her right hand and leg.
High Court’s Refusal to Quash FIR
Aggrieved by the FIR, the appellant, along with his mother and brother, filed a Criminal Miscellaneous Writ Petition before the High Court of Judicature at Allahabad, seeking the quashing of the FIR. However, the High Court, in its order dated February 27, 2024, dismissed the petition. It observed that on perusal of the FIR, “a prima facie case of commission of a cognizable offence was made out.” This order prompted the appellant to approach the Supreme Court.
Supreme Court’s Analysis and Observations
The Supreme Court undertook a detailed examination of the allegations in the FIR to determine if a case was made out against the appellant. The central issue was whether the High Court was correct in refusing to quash the criminal proceedings against him.
The bench found the allegations to be lacking in substance. The judgment states, “A bare perusal of the FIR shows that the allegations made by complainant/respondent No.2 are vague and omnibus. Other than claiming that the husband and his family along with the accused/appellant herein mentally harassed her with a demand for dowry, the complainant/respondent No.2 has not provided any specific details or described any particular instance of harassment.”
The Court noted that the FIR failed to mention crucial details. “She has also not mentioned the time, date, place, or manner in which the alleged harassment occurred or the details of the nature of demand or its particulars. Therefore, the FIR lacks concrete and precise allegations,” the bench observed.
Regarding the allegation under Section 323 IPC, the Court found no link between the alleged harassment and the complainant’s injury. It stated, “There is no remote or proximate act or omission attributed to the accused/appellant that implicates him or assigns him any specific role in the said FIR for the offence of hurt as defined under Section 319 IPC.”
The Court emphasized that specific instances are necessary to establish “cruelty” under Section 498A IPC. It observed, “mere general allegations of harassment without pointing out the specific details would not be sufficient to continue criminal proceedings against any person.”
Citing its landmark decision in State of Haryana vs. Bhajan Lal (1992), the Supreme Court held that the present case fell within the category where the allegations, “even if they are taken at their face value and accepted in their entirety do not prima facie constitute any offence or make out a case against the Accused.”
The bench also quoted a recent 2025 judgment in Dara Lakshmi Narayana vs. State of Bihar, cautioning against the misuse of law in matrimonial disputes. It noted, “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. Such generalised and sweeping accusations unsupported by concrete evidence or particularised allegations cannot form the basis for criminal prosecution.”
The Court further observed the growing trend of misusing Section 498A, stating there has been “a growing tendency to misuse provisions like Section 498A of the IPC as a tool for unleashing personal vendetta against the husband and his family by a wife.”
Final Decision
Based on its analysis, the Supreme Court concluded that it was “neither expedient nor in the interest of justice to permit the present prosecution emanating from the FIR to continue.”
The appeal was allowed, and the impugned order of the Allahabad High Court dated February 27, 2024, was set aside. Consequently, the FIR lodged at Police Station Civil Lines, Meerut, and all proceedings arising from it were quashed, but only in relation to the appellant. The Court clarified that its observations would not impact any other pending proceedings between the parties, which are to be decided on their own merits.
