The Supreme Court quashes FIR against father-in-law, mother-in-law, and sister-in-law, ruling that vague and general allegations cannot warrant prosecution under Section 498-A of the Indian Penal Code.
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NEW DELHI: The Supreme Court of India has recently delivered a landmark judgment, quashing criminal proceedings against the father-in-law, mother-in-law, and sister-in-law of a complainant. The Court ruled that the FIR lodged against them contained vague, general, and omnibus allegations, failing to establish a prima facie case under Sections 498-A, 377, and 506 of the Indian Penal Code (IPC), 1860.
The judgment was pronounced by a bench comprising Chief Justice of India B.R. Gavai, Justice K. Vinod Chandran, and Justice Atul S. Chandurkar, emphasizing that continuing such proceedings would amount to an abuse of the process of law. This decision overturns the earlier ruling by the Nagpur Bench of the Bombay High Court, which had refused to quash the FIR.
Background of the Case
The case originated from a complaint filed by the second respondent, married to Piyush, the son of the appellants, on July 14, 2021. The complainant alleged that although her family had provided gifts during the wedding, her husband’s family made additional demands.
The FIR, No. 20 of 2022, registered at Bajaj Nagar Police Station, Nagpur, on February 6, 2022, accused the husband’s family of continuing dowry demands. It also included allegations against her husband of insisting on unnatural sexual acts, allegedly causing her mental distress.
Initially registered under Section 498-A read with Section 34 IPC, offences under Sections 377 and 506 IPC were later added.
Following an investigation, the appellants sought to quash the proceedings under Section 482 of the Code of Criminal Procedure, 1973, but the High Court dismissed their application on March 19, 2024, citing prima facie evidence. Aggrieved, the appellants approached the Supreme Court.
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Arguments Before the Supreme Court
The appellants, represented by Advocates Kartik Shukul and Anurag Gharote, argued:
- The FIR did not make out any offence against them under the charged sections.
- The allegations were vague and general, lacking the necessary particulars to constitute a prima facie case.
- There were no allegations against them under Sections 377 (unnatural offences) and 506 (criminal intimidation).
The State of Maharashtra and the complainant contended that the FIR, when read as a whole, established an offence under Section 498-A IPC and that further evidence could be presented during the trial.
Supreme Court’s Analysis and Findings
The Supreme Court reaffirmed the legal principle for quashing an FIR:
“Proceedings can be quashed if the allegations, even when taken at face value, do not prima facie constitute any offence or make out a case against the accused.”
Observations by the Court include:
- Vague and General Allegations: Most allegations against the appellants were general in nature, except for a single instance where the mother-in-law allegedly demanded clothes and jewellery.
- Section 498-A IPC: Cruelty must be grave enough to drive the victim to suicide or cause serious injury, which was absent in this case.
- Sections 377 and 506 IPC: Allegations only pertained to the complainant’s husband, not the appellants, and hence no trial against them was warranted.
The Court also noted that the High Court had failed to consider the absence of specific allegations against the appellants when refusing to quash the FIR.
Final Judgment:
Relying on the precedent set in State of Haryana vs. Bhajan Lal, the Supreme Court allowed the appeal. The key directions are:
- Quash FIR No. 20 of 2022 and the final report lodged against the father-in-law, mother-in-law, and sister-in-law under Sections 498-A, 377, and 506 read with Section 34 IPC.
- The judgment does not affect proceedings against the husband, which will continue independently.
Case Title:
Sanjay D. Jain & Ors. vs State of Maharashtra & Ors.
SPECIAL LEAVE PETITION (CRL.) NO.12584 OF 2024
Read Judgment:
