Reaffirming the frameworks in State of Haryana v. Bhajan Lal [1992 Supp (1) SCC 335] and Arti Mehta v. State of Madhya Pradesh [2026 SCC OnLine SC 933], the Supreme Court has emphasised that criminal law cannot be indiscriminately extended to every family member without specific overt acts and prima facie material indicating active involvement in cruelty, harassment or dowry demand. The Court therefore quashed all proceedings against the father-in-law and mother-in-law arising out of FIR, holding that the High Court erred in restricting quashing only to Section 323 IPC.
The Apex Court reiterated that in prosecutions arising out of matrimonial disputes, allegations against each accused must be specific, distinct and supported by prima facie material indicating active participation in cruelty, harassment or unlawful demand of dowry. The Court found no material on record to show that the in-laws caused grave injury to the complainant’s life, limb, or mental or physical health, or that they harassed her for any property or valuable security to sustain Section 498A IPC.
For Sections 3 and 4 of the Dowry Prohibition Act, the Court noted that the complaint did not disclose particulars of dowry demands, occasions, presence of independent witnesses, or specific overt acts constituting cruelty. For Sections 406 and 506 IPC, the Court observed that only vague, omnibus and self-serving allegations, unsupported by independent material, could not form the basis to continue criminal proceedings against the in-laws.
Briefly, the appellants are the father-in-law and mother-in-law of the complainant (Respondent No. 2). The complainant married their son on Feb 01, 2021, as per Hindu rites and customs in Darjeeling. After the husband was transferred to Siliguri, the complainant began residing with the appellants, and a child was born out of the wedlock on July 17, 2023. Matrimonial disputes arose between the complainant and her husband, including allegations of harassment and dowry demand, following which the complainant left the matrimonial home.
On Nov 21, 2023, the complainant lodged a complaint leading to FIR at Police Station Siliguri Women, District Darjeeling, against the husband and the two appellants, under Sections 498A, 406, 506 and 323 of the Indian Penal Code, 1860 and Sections 3 and 4 of the Dowry Prohibition Act, 1961. The allegations included verbal taunts, demand for a four-wheeler as dowry, lack of nutritional and medical support during pregnancy, taunting after the birth of a girl child, and being forced on Nov 11, 2023, to sign a document declaring that she had received all her streedhan and valuables.
During investigation, the complainant’s parents were examined, and chargesheet came to be filed on Dec 21, 2023, charging the appellants and the husband under the same sections. On Aug 07, 2024, the appellants filed a petition under Section 482 CrPC seeking quashing of the chargesheet. The High Court of Calcutta partly allowed the petition and quashed only the charge under Section 323 IPC, while declining to quash the proceedings with respect to the other sections.
A Two-Judge Bench comprising Justice Nongmeikapam Kotiswar Singh and Justice N.V. Anjaria recalled the well-settled principles for quashing of FIRs under Section 482 CrPC laid down in State of Haryana v. Bhajan Lal [1992 Supp (1) SCC 335], particularly the categories where the inherent power can be exercised to prevent abuse of the process of court. The Court emphasised the peculiar nature of criminal cases arising out of domestic disputes and referred to its decisions in Arti Mehta v. State of Madhya Pradesh [2026 SCC OnLine SC 933] and Geddam Jhansi v. State of Telangana [2025 SCC OnLine SC 263].
The Apex Court observed that in prosecutions arising out of matrimonial disputes, allegations against each accused must be specific, distinct and supported by prima facie material indicating active involvement in the alleged acts of cruelty, harassment or unlawful demand of dowry. The Court also cautioned that sweeping and omnibus implication of all family members without specific allegations and prima facie material would amount to abuse of the process of law.
Examining each surviving charge, the Court noted that neither the complaint nor the investigation revealed any material showing that the appellants caused grave injury to the complainant’s life, limb, or mental or physical health, or that they harassed her for any property or valuable security to sustain Section 498A IPC. Regarding Sections 3 and 4 of the DP Act, the Court observed that the allegations did not disclose particulars of dowry demands, occasions, presence of independent witnesses, or specific overt acts constituting cruelty.
For Section 406 IPC, the Court found that the investigation did not reveal specifics of property entrusted to the appellants or any misappropriation, and only vague and omnibus allegations had been made. For Section 506 IPC, the Court noted that the only material to demonstrate coercion or intimidation by the first appellant was the complainant’s own complaint and statements of her parents recorded under Section 161 CrPC, with no other evidence on record.
