IN THE HIGH COURT OF MADHYA PRADESH AT GWALIOR BEFORE HON'BLE SHRI JUSTICE RAJESH KUMAR GUPTA ON THE 10^th OF FEBRUARY, 2026 MISC. CRIMINAL CASE No. 4038 of 2024 NAVINDRA SIKARWAR AND OTHERS Versus THE STATE OF MADHYA PRADESH AND OTHERS Appearance:

Shri Imran Khan - Advocate for the petitioners.

Shri Suyash Mohan Guru- Advocate for respondent No.2.

Shri Dinesh Savita - PP for the State.

ORDER

1. By this petition filed under Section 482 of Cr.P.C., the petitioners seek quashment of FIR bearing Crime No. 60/2023 registered at Police Station Mahila Thana, District Shivpuri, for offences punishable under Sections 498-A, 323, 34 of IPC and Sections 3/4 of the Dowry Prohibition Act, along with all consequential proceedings.

2. Brief facts of the case are that the complainant Smt. Vibha Chauhan, wife of petitioner No.1 Navindra Sikarwar, lodged a written complaint on 16.12.2023 alleging that her marriage was solemnized on 06.05.2017 according to Hindu rites and customs. It is alleged that despite sufficient dowry and household articles being given at the time of marriage as per the status of her father, the accused persons- husband, father-in-law, mother-in-law and two brothers-in-law started taunting her for bringing insufficient dowry. It is specifically alleged that after she secured employment as Junior Engineer and was posted at Dholpur, she used to visit her matrimonial home at Gwalior during holidays, and whenever all accused persons assembled together, they subjected her to mental and physical cruelty on account of dowry demand. A specific incident dated 23.06.2023 has been narrated wherein, according to the complainant, all five accused persons collectively harassed her and petitioner No.1 allegedly assaulted her. It is further alleged that a demand of ₹25,00,000/- was made and she was told that she would be accepted in the matrimonial home only upon fulfilling the said demand. On the basis of the complaint, the aforementioned FIR has been registered and investigation commenced.

3. Learned counsel for the petitioners submits the allegations are false and motivated. The complainant and petitioner No.1 were living separately due to service postings; hence no occasion for harassment arose. Petitioners No.2 to 5 reside separately and have been falsely implicated with omnibus allegations. The FIR has been lodged belatedly with malafide intention. The complainant had extra-marital involvement, and upon confrontation, she threatened false implication. The guidelines laid down in the case of Rajesh Sharma v. State of U.P., 2017 SCC OnLine SC 821 were not followed prior to registration of FIR. Reliance has been placed upon Preeti Gupta v. State of Jharkhand, (2010) 7 SCC

667 and Geeta Mehrotra v. State of U.P., (2013) 1 SCC 476.

4. Learned counsel for the respondent/State as well as counsel for the complainant/respondent No.2 vehemently opposed the prayer and prayed for its rejection.

5. Heard counsel for the rival parties and perused the entire material available on record with due care.

6. The legal position regarding quashing of FIR is no longer res integra. In State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335, the Supreme Court enumerated illustrative categories where interference may be warranted. However, the Court cautioned that such power is to be exercised sparingly.

7. In Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra, (2021) 19 SCC 401, a three-Judge Bench authoritatively held that the High Court should not stall investigation or conduct a mini-trial while exercising jurisdiction under Section 482 Cr.P.C. The Court reiterated that if the FIR discloses commission of cognizable offence, the investigation must proceed unhindered.

8. In Amit Kapoor v. Ramesh Chander, (2012) 9 SCC 460, it has been held that at the stage of quashing, the Court is required to examine only whether uncontroverted allegations prima facie establish the offence; meticulous appreciation of evidence is impermissible.

9. Further, in Kamal Shivaji Pokar