NEW DELHI: The Supreme Court on Wednesday quashed a dowry harassment case against a woman's parents-in-law and sister-in-law in Uttar Pradesh, saying that the vague allegations in matrimonial disputes should not be allowed to trigger criminal prosecution against a husband's relatives.
A bench of Justices BV Nagarathna and Ujjal Bhuyan was hearing a petition filed to challenge the Allahabad High Court order, which refused to quash an FIR lodged against the complainant's sister-in-law and parents-in-law under IPC Sections 498A (Matrimonial Cruelty), 323 (Voluntarily Causing Hurt) and provisions of the Dowry Prohibition Act.
In an order, the court said, "Time and again, this court has observed that merely stating certain vague and omnibus allegations without any cogent material evidence to support the same should not become a fillip to jump-start the criminal machinery of the State." The court said that the criminal law should not become a means of "unleashing personal vendetta" against family members of the husband, and courts must be cautious where sweeping accusations are made without concrete evidence. "A mere statement stating that the accused herein frequently demanded dowry and harassed the complainant for the same is not sufficient to initiate criminal proceedings against them when the same are not corroborated or bolstered by other materials placed on record," the bench said.
The complainant had alleged that after her marriage in April 2017, her husband and in-laws demanded Rs 8.5 lakh and a car as dowry and subjected her to cruelty. She had also accused them of assaulting her during pregnancy in 2017, leading to a miscarriage, and levelled allegations of molestation against her father-in-law. In December 2023, the Allahabad High Court refused to quash the FIR lodged in November 2023 against the complainant's sister-in-law and parents-in-law. It noted that the Investigating Officer (IO) had dropped the charge of causing miscarriage and that the medical records did not support the allegation.
The court also noted the delay of more than six years in lodging the FIR, saying the prosecution had failed to provide a satisfactory explanation. "We find that the citizens who allege commission of an offence should not dawdle on their rights but should rather pursue them in real time in order to achieve the ends of justice," the bench said, adding that such delays can be fatal in cases involving personal disputes where evidence is already limited. It further observed that the allegations against the in-laws were largely general and lacked specific details about their role.
Allowing the appeals, the court quashed the FIR, chargesheet and the pending criminal case against the complainant's sister-in-law and parents-in-law, while clarifying that its observations would not affect any other matrimonial proceedings between the parties.