The Supreme Court of India has quashed criminal proceedings against the father-in-law, mother-in-law, and sister-in-law of a complainant, ruling that the First Information Report (FIR) lodged against them contained vague, general, and omnibus allegations that did not establish a prima facie case for offences under Sections 498-A, 377, and 506 of the Indian Penal Code, 1860.
In a judgment delivered by a bench comprising Chief Justice of India B.R. Gavai, Justice K. Vinod Chandran, and Justice Atul S. Chandurkar, the Court held that the continuation of such proceedings would amount to an abuse of the process of law. The ruling came in the case of Sanjay D. Jain & Ors. vs. State of Maharashtra & Ors., overturning an order by the Nagpur Bench of the High Court of Judicature at Bombay, which had refused to quash the FIR.
Background of the Case
The case originated from a complaint filed by the second respondent, whose marriage to Piyush, the son of appellants No. 1 and 2, took place on July 14, 2021. The complainant alleged that her family had provided various gifts at the time of the wedding, but her husband’s family subsequently made further demands.
The FIR, registered as No. 20 of 2022 at Bajaj Nagar Police Station, Nagpur, on February 6, 2022, detailed allegations that the husband’s family was not satisfied with the gifts and their demands for more dowry continued. The complainant also alleged that her husband insisted on engaging in unnatural sex, causing her mental torture. Initially registered under Section 498-A read with Section 34 of the Penal Code, offences under Sections 377 and 506 were later added.
Following an investigation, a final report was filed. The appellants (the husband’s family) filed an application under Section 482 of the Code of Criminal Procedure, 1973, before the High Court, seeking to quash the criminal proceedings. The High Court dismissed the application on March 19, 2024, finding that there was prima facie material to proceed with a trial. Aggrieved by this decision, the father-in-law, mother-in-law, and sister-in-law, excluding the husband, appealed to the Supreme Court.
Arguments Before the Supreme Court
The appellants, represented by Advocates Kartik Shukul and Anurag Gharote, argued that a complete reading of the FIR did not make out any offence against them under the charged sections. They contended that the allegations were “entirely vague in nature” and lacked the specific details necessary to constitute a prima facie case. Relying on the judgment in Digambar and Another Vs. The State of Maharashtra and Another, they submitted that even if the statements in the FIR were accepted in their entirety, no case was made out. Furthermore, they asserted that there were “no allegations whatsoever” against them concerning the offences under Sections 377 (unnatural offences) and 506 (criminal intimidation).
Conversely, the State of Maharashtra and the complainant, represented by Advocates Adsh Dubey and Sachin Patil respectively, supported the High Court’s order. They argued that the complaint, when read as a whole, clearly established an offence under Section 498-A. They pointed to the complainant’s statement about a “consistent demand by the appellants for gifts and other items towards dowry” and maintained that further details could be presented as evidence during the trial.
Court’s Analysis and Findings
The Supreme Court, in its judgment, first reiterated the established legal principle for quashing an FIR: proceedings are justified to be quashed if “the allegations made in the FIR or the complaint, even when taken at their face value and accepted in their entirety do not prima facie constitute any offence or make out any case against the accused.” The Court emphasized, “Vague and general allegations cannot lead to forming of a prima facie case.”
Upon examining the FIR, the Court found that the allegations against the appellants were of a general nature. The judgment noted, “A perusal of the FIR and its consideration in entirety indicates that statements of a general nature have been made therein as against the present appellants.” The only specific instance mentioned was a call from the mother-in-law demanding clothes and jewellery. The Court observed, “Except this statement, all other statements are of a general nature as well as vague without any particulars. There are other omnibus statements made in the complaint without any particulars whatsoever.”
The Court explained that to constitute an offence under Section 498-A, the cruelty must be of a nature that could drive the victim to suicide or cause grave injury. It found that “Such allegations are absent in the present case.”
Regarding the graver offences under Sections 377 and 506, the Court’s finding was definitive. It stated, “it is seen that the allegations in this regard have been made only against the complainant’s husband and not against the present appellants. The entire tenor of the complaint in that regard seeks to implicate the complainant’s husband and all incidents stated therein relate to him. There is no allegation whatsoever in that context against the appellants that would require them to face trial on that count.”
The Supreme Court concluded that the High Court had “failed to notice this aspect of the matter” when it declined to quash the proceedings.
Final Order
Finding that a case was made out for quashing the FIR based on the touchstone of the law laid down in State of Haryana and Others vs. Bhajan Lal and Others, the Supreme Court allowed the appeal.
The Court ordered:
- FIR No. 20 of 2022 and the resulting final report lodged against the appellants under Sections 498-A, 377, and 506 read with Section 34 of the Penal Code are quashed.
- It was clarified that the adjudication shall not affect the proceedings initiated against the husband (accused No. 1), which shall be decided on their own merits.
The judgment restricts its observations to the present appellants only, ensuring that the case against the husband can proceed independently.
