Supreme Court Quashes Criminal Case Against Parents-In-Law In Matrimonial Dispute For Lack Of Specific Allegations

The Court was hearing an appeal arising out of the refusal of the High Court of Telangana to quash criminal proceedings pending against the appellants, who were the mother-in-law and father-in-law of the complainant-wife.

A Bench comprising Justice B.V. Nagarathna and Justice R. Mahadevan, while setting aside the High Court’s order, relied upon its earlier decision in Dara Lakshmi Narayana v. State of Telangana (2024) and held that “the aforesaid allegations levelled against the appellant(s), even if taken at their face value, do not prima facie disclose the commission of the alleged offences so as to warrant the initiation of criminal proceedings”.

Advocate Baglekar Akash Kumar represented the appellants, while Advocate Devina Sehgal represented the respondents.

Background

The complainant-wife lodged a complaint alleging cruelty and dowry demand against her husband and his family members, including the appellants, following matrimonial discord. Pursuant to the complaint, an FIR was registered for offences under Sections 498A, 323 and 504 read with Section 34 of the Indian Penal Code and Sections 3 and 4 of the Dowry Prohibition Act.

After completion of the investigation, a chargesheet was filed, and cognisance was taken by the Judicial First Class Magistrate (Prohibition and Excise Offence), Nalgonda, leading to registration of a case against the accused persons.

Aggrieved by the initiation of proceedings, the appellants approached the Telangana High Court under Section 482 of the Code of Criminal Procedure seeking quashing of the criminal case insofar as it related to them. The High Court declined to interfere and disposed of the petition by granting liberty to the appellants to seek discharge before the trial court.

Court’s Observation

The Supreme Court examined the allegations contained in the FIR and found that the accusations levelled against the appellants were “vague and omnibus inasmuch as there is an absence of any specific instance or occasion detailed with particulars wherein the appellants demanded dowry …and on refusal of the same, subjected her to mental and physical cruelty”.

The Bench observed that even if the allegations were taken at face value, they did not prima facie disclose the commission of the alleged offences to justify continuation of criminal proceedings against the appellants.

The Court placed reliance on its earlier judgment in Dara Lakshmi Narayana v. State of Telangana, wherein it was held that “…a mere reference to the names of family members in a criminal case arising out of a matrimonial dispute, without specific allegations indicating their active involvement, should be nipped in the bud”.

In Dara Laxmi, the Apex Court had further highlighted that “there is often a tendency to implicate all the members of the husband's family when domestic disputes arise out of a matrimonial discord”, while cautioning that “such generalised and sweeping accusations unsupported by concrete evidence or particularised allegations cannot form the basis for criminal prosecution”.

Applying these principles to the facts of the present case, the Court held that the case fell within the parameters laid down in Dara Lakshmi and warranted the quashing of proceedings.

Conclusion

In view of the foregoing, the Supreme Court set aside the impugned order passed by the High Court. The criminal proceedings pending before the Judicial First Class Magistrate were quashed insofar as they related to the appellants, who are the parents-in-law of the complainant.

The appeal was accordingly allowed, and all pending applications were disposed of.

Cause Title: MN & Anr. v. State of Telangana & Anr. (Neutral Citation: 2025 INSC 1496)

Appearances

Appellants: Advocates Baglekar Akash Kumar, Anurag, AOR, Kunwar Vishal Singh, Anmol Singh, N. Krishna Sumanth, V. Pranitha, Pinjari Rafi

Respondents: Devina Sehgal, AOR; Yatharth Kansal, Advocate

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