IN THE HIGH COURT OF MADHYA PRADESH AT GWALIOR BEFORE HON'BLE SHRI JUSTICE RAJESH KUMAR GUPTA

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ON THE 9 OF FEBRUARY, 2026 MISC. CRIMINAL CASE No. 25596 of 2025 SOHAN LAL SARGAIYAN AND OTHERS Versus THE STATE OF MADHYA PRADESH AND OTHERS Appearance:

Shri Atul Gupta - Advocate for the petitioners.

Shri Atul Kumar Sharma- PP for the State. None for respondent No.2, though served.

ORDER

1. This petition under Section 482 of the Code of Criminal Procedure (now corresponding to Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023) has been filed by the petitioners seeking quashment of FIR bearing Crime No. 164/2025 registered at Police Station Joura for offences punishable under Sections 85, 296, 351(3) and 3(5) of the Bharatiya Nyaya Sanhita, 2023 and the consequential charge-sheet filed pursuant thereto. 2. As per the prosecution case, the marriage of complainant Smt. Kiran was solemnized with co-accused Govind Narayan Sargaiyan on 03.12.2011. It is alleged that at the time of marriage, sufficient dowry and gifts were given beyond the financial capacity of the complainant’s father. The complainant resided with her husband at Gwalior. According to her, for about two years the matrimonial life remained cordial. Thereafter, it is alleged that the husband along with the present petitioners started demanding an additional amount of Rs. 20,00,000/- from her parental family and subjected her to cruelty and harassment on account of non-fulfilment of the said demand. On 29.04.2025, the complainant lodged the impugned FIR at Police Station Joura. After investigation, the police have filed charge-sheet against the accused persons including the present petitioners. It is also not in dispute that prior to lodging of the FIR, the husband Govind had filed a petition seeking divorce before the Family Court, Gwalior on 03.03.2025.

Being aggrieved by the aforesaid, the instant petition has been preferred.

3. Learned counsel for the petitioners submits that the allegations are vague and omnibus in nature without specific dates or overt acts attributed to the petitioners. The petitioners are residing separately in a different city and have been falsely implicated. The FIR has been lodged as a counterblast to the divorce petition filed by the husband. There is a growing tendency to implicate all relatives of the husband in matrimonial disputes.

Learned counsel for the petitioner while placing reliance on the following judgements, contended as follows:-

4. In Dara Lakshmi Narayana v. State of Telangana, 2024 SCC OnLine SC 3682, the Supreme Court quashed criminal proceedings under Section 498A IPC and Sections 3 and 4 of the Dowry Prohibition Act. It noted that the allegations lacked specific instances of cruelty or dowry demands, and merely naming family members without concrete evidence amounts to abuse of legal process. The Court said that "a mere reference to the names of family members in a criminal case arising out of a matrimonial dispute, without specific allegations indicating their active involvement should be nipped in the bud". The Court emphasised that such misuse of Section 498A to harass the husband and his family must be curbed, and held that the High Court erred in not quashing the FIR under Section 482 of the CrPC. The Court further said that the "inclusion of Section 498-A of the IPC by way of an amendment was intended to curb cruelty inflicted on a woman by her husband and his family, ensuring swift intervention by the State. However, in recent years, as there have been a notable rise in matrimonial disputes across the country, accompanied by growing discord and tension within the institution of marriage, consequently, there has been a growing tendency to misuse provisions like Section 498-A of the IPC as a tool for unleashing personal vendetta against the husband and his family by a wife.

5. In Archin Gupta v. State of Haryana (2025) 3 SCC 756, the Supreme Court held that Section 498A IPC should not be applied mechanically. The Cour