Vague & General Allegations Cannot Form Prima Facie Case: Supreme Court Quashes FIR U/S.498A IPC Against In-Laws

The Supreme Court quashed FIR under Section 498A IPC lodged by a woman against her father-in-law, mother-in-law and sister-in-law observing that vague and general allegations cannot lead to forming of a prima facie case.

The Court reiterated that, in the absence of intention to cause grave injury or to drive the victim to commit suicide or inflict grave injury to herself, the ingredients for the offence of cruelty cannot be made out.

The Bench of Chief Justice B.R Gavai, Justice K. Vinod Chandran and Justice Atul S. Chandurkar observed, “Vague and general allegations cannot lead to forming of a prima facie case...The cruelty caused by the husband and his family members should be of such nature that it is inflicted with the intention to cause grave injury or drive the victim to commit suicide or inflict grave injury to herself. Such allegations are absent in the present case. We do not find that on a complete reading of the complaint, a prima facie case for proceeding under Section 498-A of the Penal Code has been made out against the appellants.”

Advocate Kartik Shukul represented the Appellant, while Advocates Adarsh Dubey and Sachin Patil represented the Respondents.

Case Brief

An Appeal was filed by father-in-law, mother-in-law and sister-in-law of the complainant, being aggrieved by the rejection of their application seeking quashing of the FIR lodged against them for the offences punishable under Sections 498-A, 377 and 506 read with Section 34 of the Indian Penal Code, 1860.

The Complainant contended that after her marriage, , the demand for further gifts was made by the family of the husband from time to time. It was also the case of the Complainant that her husband insisted upon her to engage in unnatural sex, which resulted in causing her mental torture. Accordingly, an FIR was lodged against the husband and in-laws of the Complainant. However, the same was dismissed by the High Court.

The Appellants contended that the ingredients necessary for invoking the said provisions were absent in the FIR and hence, no offence could have been registered against the appellants. The allegations as made were entirely vague in nature and in the absence of any details whatsoever it could not be said that even a prima facie case had been made out for proceeding with the trial.

Court’s Observation

The Court opined that the FIR against the Appellants under offence of Sections 498-A, 377 and 506 read with Section 34 of the Penal Code deserve to be quashed.

The Bench underscored the parameters that were to be borne in mind while entertaining the prayer for quashing of the FIR. The Court said, “If the allegations made in the FIR or the complaint, even when taken at their face value and accepted in their entirety do not prima facie constitute any offence or make out any case against the accused, quashing of the proceedings would be justified. Vague and general allegations cannot lead to forming of a prima facie case.”

While referring to Section 498A IPC, the Court opined that the ingredients for making out an offence punishable under Section 498A IPC, the requirement is that there has to be cruelty inflicted against the victim which either drives her to commit suicide or cause grave injury to herself or lead to such conduct that would cause grave injury or danger to life, limb or health. The latter part of the provision refers to harassment with a view to satisfy an unlawful demand for any property or valuable security raised by the husband or his relatives.

The Court observed that the statements of a general nature have been made, without any particulars, against the Appellants.

“The cruelty caused by the husband and his family members should be of such nature that it is inflicted with the intention to cause grave injury or drive the victim to commit suicide or inflict grave injury to herself. Such allegations are absent in the present case. We do not find that on a complete reading of the complaint, a prima facie case for proceeding under Section 498-A of the Penal Code has been made out against the appellants”, the Court held.

Cause Title: Sanjay D. Jain & Ors. V. State of Maharashtra & Ors. (Neutral Citation: 2025 INSC 1168)

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