The Gujarat High Court quashed an FIR under Section 498A against a father-in-law and mother-in-law, citing vague allegations and lack of evidence. The judgment reinforces action against the misuse of law in matrimonial disputes.
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AHMEDABAD: In a judgment, the Gujarat High Court quashed a First Information Report (FIR) filed under Sections 498A, 323, 506(2), 504, and 114 of the Indian Penal Code against the father-in-law and mother-in-law of the complainant.
The Court held that the allegations made against them were vague, general, and omnibus, lacking any specific role or evidence. Continuing the criminal trial, the Court observed, would amount to an abuse of the judicial process.
This decision reaffirms the judiciary’s consistent stand against the misuse of Section 498A IPC, especially in matrimonial disputes where all family members are often implicated without specific allegations.
Background of the Case
The complainant registered FIR No.11211001230008/2023 at Mahila Police Station, Surendranagar, accusing her husband and in-laws of cruelty and harassment.
During the hearing:
- Applicant No.1 (the husband) chose to withdraw his request for quashing.
- Applicants No.2 and No.3, the father-in-law and mother-in-law, continued their plea under Section 482 CrPC seeking quashing of the FIR.
The defence argued that:
- They lived separately in Porbandar, while the complainant resided in Dhrangadhra.
- The FIR contained no specific acts attributed to them.
- Allegations were general in nature, stating only that they “incited” their son.
Court’s Observations
Justice Vimal K. Vyas made several critical observations:
1. No Specific Allegations
The Court noted that the FIR did not contain any clear role, incident, or action attributable to the in-laws. The accusations were vague, lacking necessary particulars.
2. Physical Distance Weakens Allegations
Since the in-laws resided in Porbandar and had no proximity to the complainant in Dhrangadhra, the Court found the allegations improbable.
3. Criminal Proceedings Would Be Futile
Given the lack of evidence, continuation of the trial would be:
- A futile exercise
- An abuse of process
- A cause of unnecessary harassment to the accused
The judgment heavily relied on the Supreme Court’s landmark rulings, especially:
Shobhit Kumar Mittal vs. State of Uttar Pradesh (2025 INSC 1152)
The Supreme Court emphasized that:
- Family members should not be roped into criminal cases without clear and specific allegations.
- Misuse of Section 498A IPC has increased in matrimonial disputes.
- Courts must nip in the bud cases where allegations are intended as pressure tactics.
Dara Lakshmi Narayana vs. State of Bihar (2025) 3 SCC 735
Key points highlighted:
- Over-implication of in-laws is a “judicially recognized” trend.
- Vague allegations cannot justify criminal prosecution.
- Section 498A aims to protect genuinely harassed women, not to settle personal scores.
The High Court held that:
- There is no likelihood of conviction based on such a weak FIR.
- All proceedings arising from Criminal Case No. 2321/2023 are quashed only against Applicants No. 2 and 3.
The Court made the rule absolute and clarified that all consequential proceedings arising from the impugned FIR also stood terminated with respect to the applicants.
Case Title:
BHARATBHAI RAVAL & ORS. Versus STATE OF GUJARAT & ORS.
R/CRIMINAL MISC.APPLICATION (FOR QUASHING & SET ASIDE FIR/ORDER) NO. 1980 of 2024
READ ORDER