Justice Ahsanuddin Amanullah, Justice Prashant Kumar Mishra, Supreme Court
Supreme Court Highlights Growing Trend Of Dowry Victims Arraigning Relatives Of Husband, Quashes Case Against Sister-In-Law & Other Family Members
|The Appeal before the Supreme Court was filed by the appellants challenging the order dismissing their petition for quashing proceedings initiated against them.
While quashing a case filed by a woman against her sister-in-law and other family members, the Supreme Court has highlighted the growing trend of the dowry victim arraigning the relatives of the husband in dowry-related matters.
The Appeal before the Apex Court was filed by the appellants challenging the order passed by the High Court whereby their petition under Section 482 CrPC for quashing proceedings on the file of the Special Judicial Magistrate, Ist Class for Prohibition & Excise Cases was dismissed.
The Division Bench of Justice Ahsanuddin Amanullah and Justice Prashant Kumar Mishra said, “Considering the growing trend of the dowry victim arraigning the relatives of the husband, this Court in the matter of Geeta Mehrotra & Anr. vs. State of Uttar Pradesh & Anr. has deprecated the practice involving the relatives of the husband for the offence under Section 498A IPC and Section 4 of Dowry Prohibition Act, 1961.”
AOR Venkateswara Rao Anumolu represented the Appellant, while Senior Advocate Abhijit Basu represented the Respondent.
Factual Background
The marriage between the de facto complainant (second respondent) with Challa Poornananda Reddy (A1) was solemnised in 2014 at Guntur. After five months of marriage, the de facto complainant left the company of her husband and joined her parents to live at her parental house at Vidyanagar, Guntur. On persuasion, she joined her husband but again went back to her parental house, and this act continued for some more time, compelling the husband to send a legal notice followed by a petition for restitution of conjugal rights.
On the intervention of elders, a compromise was reached. However, the complainant later left for the USA without informing her husband or his family members, and the dispute continued. The husband moved a petition for dissolution of marriage, and she again lodged a police complaint against six accused persons, including the present appellants. The first appellant is the sister-in-law of the de facto complainant, the second appellant is the husband of the first appellant, and the third appellant is the father-in-law of the first appellant.
Reasoning
On a perusal of the records and the facts of the case, the Bench noted that omnibus and general allegations were made against the appellants. There was no denial of the fact that the appellants reside at Hyderabad, whereas the de facto complainant stayed at Guntur in her marital house. There was no specific date as to when the present appellants visited Guntur and joined the other accused persons in demanding dowry from the de facto complainant.
The allegation was only of taunts made by them, saying that they were highly placed, having political influence and connection with Ministers and thus, they instigated the accused persons to pressurise the de facto complainant to get additional dowry.
The Bench took note of the admitted position that the appellants are residing at Hyderabad, whereas the de facto complainant stayed in her marital house at Guntur at the relevant point of time. She is presently staying in the USA. “There is omnibus allegation against the appellants that they too used to demand dowry or instigate accused nos. 1 to 3 who are not before us, in demanding dowry”, it said
Considering the facts and circumstances in their entirety, the Bench quashed the case agaisnt the appellants.
Cause Title: Muppidi Lakshmi Narayana Reddy & Ors. v. The State of Andhra Pradesh & Anr. (Neutral Citation: 2025 INSC 562)
Appearance:
Appellants: AOR Venkateswara Rao Anumolu
Respondent: Senior Advocate Abhijit Basu, Advocate Prerna Singh, AOR Guntur Pramod Kumar, Advocates Dhruv Yadav, Byrapaneni Suyodhan, AOR Tatini Basu,