Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2025 Supreme(SC) 1185

SUPREME COURT OF INDIA
B. V. Nagarathna, K.V. Viswanathan, JJ.
Mange Ram – Appellant
Versus
State Of Madhya Pradesh & Another – Respondents
Criminal Appeal No. 3470 of 2025 (Arising out of Special Leave Petition (Criminal) No. 10817 of 2024)
Decided On : 12-08-2025

Advocates appeared:
For the Petitioner(s) Mr. Yusuf, AOR Mr. Amarjeet Singh Girsa, Adv. Ms. Ritu Solanki, Adv. Mr. Amit Arora, Adv. Mr. Jatin Sharma, Adv. Mr. Deepak Dahiya, Adv. Dr. Ram Sankar, Adv. Mr. Ajith Williyam S, Adv.
For the Respondent(s): Mr. Amit Sharma, A.A.G. Ms. Mrinal Gopal Elker, AOR Mr. Suarabh Singh, Adv. Mr. Aditya Chaudhary, Adv. Mr. Chinmoy Chaitanya, Adv.

IMPORTANT POINT
Matrimonial cruelty – Where matrimonial relationship has come to an end by way of divorce, and parties have since settled in their respective lives, criminal prosecution emanating from that past relationship ought not to be permitted to linger as a means of harassment – Power under Article 142 must be invoked to advance cause of complete justice in matters of this nature.

Headnote:
Indian Penal Code, 1860 – Sections 498A and 34 read with Sections 3 and 4 of Dowry Prohibition Act, 1961 – Criminal Procedure Code, 1973 – Section 482 – Constitution of India – Article 142 – Cruelty and dowry offences – Quashing petition – Appellant is father-in-law of respondent – High Court quashed criminal proceedings against mother-in-law and sister-in-law of respondent – Appellant’s son and respondent have since parted ways pursuant to decree of divorce which has attained finality – Once marital relationship between principal parties stands legally dissolved, continuation of criminal proceedings arising out of discord of that relationship serves little purpose – Continuation of proceedings against appellant would neither advance cause of justice nor serve any practical purpose – It would only perpetuate hostility between parties who appear to have otherwise moved on with their lives – Where matrimonial relationship has come to an end by way of divorce, and parties have since settled in their respective lives, criminal prosecution emanating from that past relationship ought not to be permitted to linger as a means of harassment – Continuation of criminal proceedings against appellant, which emanate solely from erstwhile matrimonial relationship, would serve no useful purpose – Further prosecution would only prolong bitterness and prove counterproductive to ends of justice – Power under Article 142 must be invoked to advance cause of complete justice in matters of this nature – Law must be applied in a manner that balances need to address genuine grievances with equally important duty to prevent its misuse – In appropriate cases, power to quash such proceedings is essential to uphold fairness and bring about a quietus to personal disputes that have run their course – FIR as well as charge-sheet against appellant quashed – Appeal allowed. (Paras 8, 24, 26, 28, 33 and 34)
Facts of the case:
By common order dated 07.05.2024, the High Court partly allowed the petitions. The High Court quashed the criminal proceedings against the mother-in-law and sister-in-law of respondent No. 2 in Misc. Criminal Case No. 50062 of 2019 on the ground that the allegations levelled against them were general in nature and lacked specific attribution of any overt act. However, the High Court refused to quash the criminal proceedings pending against the appellant and the appellant’s son.
Findings of Court:
In appropriate cases, power to quash such proceedings is essential to uphold fairness and bring about a quietus to personal disputes that have run their course.
Result : Appeal allowed.

Table of Content
1. background of the marriage and initial allegations (Para 2 , 3 , 4 , 5 , 6)
2. arguments regarding motives and lack of immediate complaints (Para 11 , 12 , 13 , 14)
3. question of belated allegations and context of divorce (Para 22 , 23 , 24)
4. judicial trends against misuse of criminal law in marital cases (Para 25 , 26 , 27)
5. court's decision to quash fir for complete justice (Para 33 , 34)

JUDGMENT :

NAGARATHNA, J.

Leave granted.

2. Briefly stated, the facts of the case are that the appellant is the father-in-law of respondent No.2. In April 2017, respondent No.2 came into contact with the appellant’s son through a matrimonial website. What began as a digital acquaintance soon developed into a personal relationship.

3. The marriage between respondent No.2 and the appellant’s son was solemnised on 23.12.2017 in accordance with the provisions of the Special Marriage Act, 1954. However, by April 2019, differences appear to have arisen between the couple. On 15.05.2019, respondent No.2 left the matrimonial home and returned to her parental residence at Jabalpur. It is stated that she informed her family of the mental and physical cruelty allegedly meted out to her by her husband and his family members.

4. Respondent No.2 approached the Mahila Police Station, Jabalpur and pursuant to her complaint, both parties were called for counselling. While the appellant’s son was to appear for the first session of counselling which took place on 26.05.2019, he was in fact present during the second session conducted on 02.06.2019. That session, which was also attended by members of both families, culminated in an understanding that the marriage would be solemnised again, this time through customary Hindu rites, within two months.

5. However, the accord reached did not last long. Disputes appear to have resurfaced shortly thereafter. Respondent No.2 once again left the matrimonial home. On 21.07.2019, she lodged First Information Report (“FIR”) No.58 of 2019 at Mahila Police Station, Jabalpur, naming her husband i.e., the appellant’s son, the appellant herein (her father-in-law), mother-in-law and sister- in-law as accused under Sections 4 98A and 34 of the INDIAN PENAL CODE , 1860 (“IPC”) and Sections 3 and 4 of the Dowry Prohibition Act, 1961 (“Dowry Act”). As per the contents of the FIR, respondent No.2 alleged that soon after the counselling sessions, fresh demands were made by the appellant and his wife, including a sum of Rupees five lakhs in cash, gold ornaments, a motor car, clothing, and other customary articles. It was further alleged that they insisted upon the ceremonial Hindu marriage being held at a respectable hotel.

6. While there was, at first, some indication of conciliation, the situation deteriorated soon thereafter. The appellant is alleged to have called respondent No.2 to Jabalpur Railway Station, where he publicly admonished her, slapped her, and threatened to ruin her life, expressing his displeasure at having been summoned to the police station. It is further alleged that he reiterated the dowry demand, which, according to the complainant, was subsequently enhanced to Rupees ten lakhs. Thereafter, the charge sheet was filed on 18.08.2019 against the appellant, the appellant’s son and other family members.

7. Being aggrieved by the continuation of the criminal proceedings, the appellant herein, who is the father-in-law of respondent No.2, along with his son, who is the husband of respondent No.2 and other family members, approached the High Court by filing Misc. Criminal Case No.30559 of 2022 and Misc. Criminal Case No.50062 of 2019 under Section 482 of the Code of Criminal Procedure, 1973 (“CrPC”), seeking quashing of FIR No.58 of 2019 registered at Police Station Mahila Thana, Jabalpur, and all consequential proceedings arising therefrom.

8. By common order dated 07.05.2024, the High Court partly allowed the petitions. The High Court quashed the criminal proceedings against the mother-in-law and sister-in