The Patna High Court clarified that the matrimonial dispute is not an offense against society, but rather a private conflict between spouses, and reiterated that offences arising out of matrimonial disputes, particularly relating to dowry or a family dispute where wrong is committed to the victim by the offenders and their family, can be settled amicably.
The Court added that the law in respect of matrimonial disputes between husband and wife is well settled, as per which the family members of the husband should not be roped unnecessarily. Reference was made to the decision of the Apex Court in the case of Naushey Ali vs State of Uttar Pradesh [(2025) 4 SCC 78].
Emphasizing that the entire family members, as well as relatives, are made accused along with the husband to face criminal prosecution, a Single Judge Bench of Justice Purnendu Singh quashed the dowry-related criminal proceedings against in-laws of the complainant under Sections 498A, 341, 323, and 34 of the Indian Penal Code (IPC), holding that the allegations were vague and lacked specific details.
However, while granting relief to the in-laws, the Court directed the mother-in-law, a serving police inspector, to take steps to reconcile the strained matrimonial relationship between her son and daughter-in-law and ordered her to pay Rs. 25,000 per month towards the welfare and maintenance of her two grandchildren.
Briefly, in this case, an FIR was filed alleging that the complainant (opposite party) was subjected to cruelty and harassment by her husband and in-laws for non-fulfilment of dowry demands. The accused-petitioners, including the husband’s sisters, brothers-in-law, and mother, therefore, sought for quashing of the entire criminal proceedings. Additionally, the petitioners contended that they lived separately, had no involvement in the matrimonial life of the couple, and were implicated merely due to their relationship with the husband.
Appearances:
Advocate Manindra Kishore Singh, for the Petitioner
Advocates Manish Kumar Singh and Dr. Ajeet Kumar, for the Opposite Party
