1. Matrimonial dispute — Allegations of dowry demand and cruelty — Complaint under Section 498A IPC and Dowry Prohibition Act — Quashing petition under Section 482 CrPC. (Para 4 , 5 , 6 , 7 , 8 , 9 )
Back
Next 
2025 Supreme(SC) 2112
SUPREME COURT OF INDIA
B.V. NAGARATHNA, R. MAHADEVAN, JJ.
Maram Nirmala & Anr. – Appellants
Versus
The State of Telangana & Anr. – Respondents
Criminal Appeal No. 5509 of 2025 (Arising out of SLP (Crl.) No. 7597 of 2025)
Decided On : 16-12-2025
Important Points
IMPORTANT POINT
Cruelty and dowry offences – Criminal prosecution cannot proceed on vague and omnibus allegations.
Cruelty and dowry offences – Criminal prosecution cannot proceed on vague and omnibus allegations.
Subject
Criminal Law - Dowry and Domestic Violence
Act Referred
Headnote
Indian Penal Code, 1860 – Sections 498A, 323 and 504 read with Section 34 and Sections 3 and 4 of Dowry Prohibition Act, 1961 – Criminal Procedure Code, 1973 – Section 482 – Cruelty and dowry offences – Common intention – Cognizance of offences – Allegations made by respondent are vague and omnibus inasmuch as there is absence of any specific instance or occasion detailed with particulars wherein appellant(s) demanded dowry from respondent and on refusal of same, subjected her to mental and physical cruelty – Only allegations levelled by respondent against appellants are that subsequent to birth of her daughter, conduct of her husband underwent change, which is stated to have been on account of alleged inducement exercised by her in-laws including appellant(s) for the purpose of demanding additional dowry – Allegations levelled against appellant(s), even if taken at their face value, do not prima facie disclose commission of alleged offences so as to warrant initiation of criminal proceedings – Impugned order of High Court set aside and criminal proceedings qua appellants quashed. (Paras 14, 15 and 18)
Facts of the case:
Trial court took cognizance of offences under Sections 498A, 323, 504 read with Section 34 of IPC and under Section 3 and 4 of DP Act alleged against respondent No.2’s husband and the appellant(s) herein. Being aggrieved, the appellant(s) preferred a petition bearing Criminal Petition No.3995/2023 before High Court under Section 482 of the Code of Criminal Procedure, 1973, seeking quashing of the proceedings in C.C. No.338/2023 pending before trial court. By impugned order dated 20.02.2025, High Court recorded its unwillingness to interfere with criminal proceeding pending against appellant(s) and disposed of quashing petition by reserving liberty to apply for discharge before concerned court.
Findings of Court:
Proceedings instituted against appellant(s) pending on file of Judicial First Class Magistrate (Prohibition and Excise offence) at Nalgonda stand quashed in relation to appellants.
Result : Appeal allowed.
Legal Category Hierarchy
- crime and sentencing
- practice and procedure
- family law
Advocates appeared:
For the Petitioner(s): Mr. Baglekar Akash Kumar, Adv. Mr. Anurag, AOR Mr. Kunwar Vishal Singh, Adv. Mr. Anmol Singh, Adv. Mr. N. Krishna Sumanth, Adv. Mr. V. Pranitha, Adv. Mr. Pinjari Rafi, Adv.
For the Respondent(s): Ms. Devina Sehgal, AOR Mr. Yatharth Kansal, Adv.
For the Petitioner(s): Mr. Baglekar Akash Kumar, Adv. Mr. Anurag, AOR Mr. Kunwar Vishal Singh, Adv. Mr. Anmol Singh, Adv. Mr. N. Krishna Sumanth, Adv. Mr. V. Pranitha, Adv. Mr. Pinjari Rafi, Adv.
For the Respondent(s): Ms. Devina Sehgal, AOR Mr. Yatharth Kansal, Adv.
Table of Contents
2. Appellants sought quashing of criminal proceedings on the ground that allegations were vague and lacked specific instances of their active involvement. (Para 9 , 12 )
3. Allegations against in-laws were vague and omnibus, lacking specific particulars of dowry demands or cruelty, failing to prima facie disclose the commission of offences. (Para 14 , 15 )
4. Generalised and sweeping accusations against family members in matrimonial disputes, without specific allegations of active involvement, constitute an abuse of process and warrant quashing. (Para 17 )
5. High Court order set aside — Criminal proceedings against the appellants quashed — Appeal allowed. (Para 18 , 19 )
6. When should criminal proceedings against in-laws in matrimonial disputes be quashed?
Proceedings should be quashed when allegations are vague, generalised, and omnibus, lacking specific instances or particulars indicating the active involvement of family members in the alleged cruelty or dowry demands. (Para 14 , 15 , 17 )
7. What is the judicial view on the tendency to implicate all family members in Section 498A IPC cases?
There is a recognized tendency to implicate all members of the husband's family during matrimonial discord. Such sweeping accusations unsupported by concrete evidence should be nipped in the bud to prevent misuse of legal processes. (Para 17 )
8. How should courts treat the potential misuse of Section 498A IPC?
Courts must exercise caution to prevent the misuse of Section 498A IPC as a tool for personal vendetta or arm-twisting tactics, ensuring prosecution only proceeds when a clear prima facie case exists. (Para 17 )
JUDGMENT
B.V. NAGARATHNA, J.
Leave granted.
2. Although respondent No.2 was served on 10.06.2025, there is no appearance on her behalf.
3. Being aggrieved by the order dated 20.02.2025 passed by the High Court for the State of Telangana at Hyderabad in Criminal Petition No.3995/2023, the appellants are before this Court.
4. Briefly stated, the facts of the case are that respondent No.2 herein is the complainant and appellant Nos.1 and 2 are the accused mother-in-law and father-in-law, respectively. Marriage between respondent No.2 and the son of the appellant(s), namely, Maram Kalyan, was solemnised on 12.08.2012 at L.B Nagar, Hyderabad. Out of wedlock, a girl child, namely Thanugnya Sri, was born on 01.11.2013.
5. On 04.03.2023, respondent No.2 filed a complaint with the SHO, Women P.S., Nalgonda alleging that at the time of the marriage, on the demand made by her husband and his family members, respondent No.2’s family had given Rupees Four Lakhs Fifty Thousand in cash, 9 tolas (90 gms.) of gold ornaments and domestic utensils. It was stated that respondent No.2 and her husband lived happily together for eight years. However, after the birth of their daughter, the husband of respondent No.2, influenced by the words of the appellant(s), sister-in- law and sister-in-law’s husband, started abusing her in vulgar language and used to beat her, demanding additional dowry of Rupees Four Lakhs. To resolve the matrimonial discord between the parties, a panchayat was convened on the request of respondent No.2 and her family. However, to respondent No.2’s dismay, her husband did not attend the panchayat meeting.
6. Thereafter, respondent No.2 filed a complaint with the SHO, Women P.S., Nalgonda pursuant to which, a counselling session for her husband and appellant(s) was conducted, wherein her husband assured that he would treat his wife and daughter well. Despite such assurances, respondent No.2 was severely beaten by her husband and his family, including the appellant(s) herein, who demanded additional dowry. In view of the foregoing circumstances, respondent No.2 was forced out of her matrimonial home. Furthermore, respondent No.2, for the past two years, was trying to contact her husband, but he did not respond to her phone calls, abandoning respondent No.2 and their daughter without any financial or emotional support.
7. Subsequent to the aforesaid complaint, on 04.03.2023, FIR bearing No.28/2023 came to be registered with P.S. Nalgonda Women P.S., District Nalgonda against six accused persons including the appellant(s) herein for the offences punishable under Sections 4 98A, 323, 504 read with Section 3 4 of the INDIAN PENAL CODE , 1860 (for short, “IPC”) and under Section 4 of the Dowry Prohibition Act, 1961 (for short, “DP Act”). On 18.03.2023, after completion of the investigation, the I.O., Women PS, Nalgonda, filed a chargesheet bearing No.38/2023 against the accused persons under Sections 4 98A, 323, 504 read with Section 3 4 of the IPC and under Section 3 and 4 of the DP Act. A case bearing C.C. No.338/2023 was committed to the Special Judicial First Class Magistrate (Prohibition and Excise Offence) at Nalgonda (for short, “trial court”).
8. The trial court, by its order dated 02.05.2023, took cognisance of the offences under Sections 4 98A, 323, 504 read with Section 3 4 of the IPC and under Section 3 and 4 of the DP Act alleged against respondent No.2’s husband and the appellant(s) herein.
9. Being aggrieved, the appellant(s) preferred a petition bearing Criminal Petition No.3995/2023 before the High Court under Section 482 of the Code of Criminal Procedure, 1973 (for short, “CrPC”), seeking quashing of the proceedings in C.C. No.338/2023 pending before the trial court.
10. By the impugned order dated 20.02.2025, the High Court recorded its unwillingness to interfere with the criminal proceeding pending against the appellant(s) and disposed of the quashing petition by reserving liberty to apply for discharge before the concerned
