In a judgment reiterating the need to prevent misuse of Section 498A of the Indian Penal Code, the Supreme Court has quashed criminal proceedings against three relatives of a husband, observing that vague and omnibus allegations made without specific details do not justify prosecuting family members in matrimonial disputes. The decision was rendered on April 23, 2025, by a bench comprising Justice Prashant Kumar Mishra and Justice Ahsanuddin Amanullah in Muppidi Lakshmi Narayana Reddy & Ors. vs. State of Andhra Pradesh & Anr., Criminal Appeal arising out of SLP (Crl.) No. 2570 of 2018.
Summary of the Case
The appeal before the Supreme Court challenged the judgment of the Andhra Pradesh High Court, which had refused to quash proceedings pending in C.C. No. 359 of 2016 before the Special Judicial Magistrate, First Class (Prohibition & Excise Cases), Guntur. The proceedings arose from an FIR filed by the de-facto complainant—wife of one Challa Poornananda Reddy—alleging harassment and dowry demands by her husband and his family members, including the appellants: his sister-in-law (A4), her husband (A5), and her father-in-law (A6).
The appellants sought relief under Section 482 CrPC to quash the proceedings, asserting that they had been falsely implicated despite not residing with the complainant or being part of any matrimonial discord.
Background and Allegations
The marriage between the complainant and accused no. 1 was solemnised on May 24, 2014. According to the complaint, the relationship deteriorated within a few months, leading the complainant to repeatedly leave the matrimonial home and return to her parental residence. This pattern led to legal proceedings: a restitution petition filed by the husband and a counter-complaint by the wife. These were temporarily settled through a compromise in April 2015.
However, further discord arose when the complainant left for the United States without informing her husband or his family. In June 2016, the husband filed for divorce, following which the complainant registered a fresh FIR in July 2016 (FIR No. 79/2016) under Section 498A IPC and Section 4 of the Dowry Prohibition Act, naming six persons including the appellants.
The complaint alleged that the appellants, despite residing in Hyderabad, would visit Guntur and instigate the husband and his parents to demand dowry. Specific mention was made of a demand for ₹5,00,000 and taunts implying that the husband could have secured ₹10 crores in dowry had he married elsewhere.
Supreme Court’s Analysis
After hearing the parties and examining the record, the bench observed that the allegations against the appellants were generic and lacked specific instances of wrongdoing. Justice Prashant Kumar Mishra, delivering the judgment, noted that there were no details as to the time, place, or nature of the alleged harassment or dowry demand involving the appellants.
The Court remarked:
“There is no specific date as to when the present appellants visited Guntur and joined accused nos. 1 to 3 in demanding dowry from the de-facto complainant. The allegations are omnibus and general.”
Importantly, the bench emphasized that the present case reflects a growing trend of implicating extended relatives of the husband in matrimonial disputes without credible basis.
In doing so, the Court relied on its earlier rulings, including Geeta Mehrotra & Anr. v. State of Uttar Pradesh & Anr. [(2012) 10 SCC 741], where it deprecated the practice of indiscriminately involving relatives of the husband. The Court also cited the more recent case of Dara Lakshmi Narayana & Ors. v. State of Telangana & Anr. [(2024) INSC 953], reiterating that such practices constitute an abuse of the legal process.
In Dara Lakshmi Narayana, the Court had made strong observations:
“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.”
The Court further warned:
“Such generalised and sweeping accusations unsupported by concrete evidence or particularised allegations cannot form the basis for criminal prosecution.”
Quashing of Proceedings
Noting that the appellants were residing in Hyderabad and not in the complainant’s matrimonial home in Guntur, the bench observed that there was no prima facie case to proceed against them. The Court held that continuing the criminal prosecution would amount to abuse of the process of law.
The judgment concluded:
“Considering the entire facts of the case, and relying on this Court’s previous decisions in Geeta Mehrotra and Dara Lakshmi Narayana, the present criminal case against the appellants deserves to be quashed. Accordingly, the appeal is allowed and Criminal Case No. 359 of 2016 against the appellants is quashed.”
Citation: Muppidi Lakshmi Narayana Reddy & Ors. vs. State of Andhra Pradesh & Anr., Criminal Appeal No. ______ of 2025 (Arising out of SLP (Crl.) No. 2570 of 2018)
