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2026 Supreme(Online)(MP) 3600

HIGH COURT OF MADHYA PRADESH
Sulekha Kushwah – Appellant
Versus
The State Of Madhya Pradesh – Respondent
MCRC 50895/2021



Advocates:
Anurag Gohil,Advocate General

IN THE HIGH COURT OF MADHYA PRADESH AT JABALPUR BEFORE HON'BLE SHRI JUSTICE HIMANSHU JOSHI ON THE 25th OF FEBRUARY, 2026 MISC. CRIMINAL CASE No. 50895 of 2021 SULEKHA KUSHWAH AND OTHERS Versus THE STATE OF MADHYA PRADESH AND OTHERS Appearance:

Shri Anurag Gohil - Advocate for the applicants.

Smt. Pushpanjaly Dwivedi - Panel Lawyer for the respondent-

State.

ORDER The present petition has been filed under Section 482 of the Cr.P.C., invoking the inherent jurisdiction of this Hon’ble Court for quashment of FIR/Crime No.439/2020 registered at Police Station Bina, District Sagar, for the offences punishable under Sections 498-A and 34 of the Indian Penal Code, 1860, and Sections 3 and 4 of the Dowry Prohibition Act, 1961, along with all consequential proceedings arising therefrom, including RCT No.186/2021 pending before the Court of learned Judicial Magistrate First Class, Bina, District Sagar.

2. The facts of the case are that the applicants are sister-in-law (nanand) of respondent no.2. The marriage of Respondent No. 2 with Rohit Kushwah, the husband and brother of the present applicants, was solemnized on 18.04.2017 at Bina, District Sagar, in accordance with Hindu rites and rituals. Since the very inception of the matrimonial relationship, the conduct and attitude of Respondent No. 2 towards the applicants and other members of the family was cruel. She habitually indulged in heated altercations and quarrels with her husband, as well as with his mother and sister, over trivial and insignificant matters, thereby disturbing the peace and harmony of the matrimonial home. Respondent No. 2 persistently exerted undue pressure upon her husband to reside separately from his parents and to sever all relations with his family members. It is further submitted that Respondent No. 2 extended threats to the husband and his family warning them of serious and adverse consequences in the event her demands were not fulfilled.

3. Learned counsel for the applicants contends that Respondent No. 2 has lodged the complaint against the present applicants on the basis of false, frivolous, and vague allegations. It is further contended that the complaint has been filed after an inordinate and unexplained delay of approximately eight months, and no satisfactory explanation has been given by Respondent No. 2 with regard to the cause of such delay. It is also submitted that neither the complaint nor the First Information Report discloses any specific or overt act attributable to the present applicants in relation to the alleged demand of dowry or acts of cruelty. Learned counsel submits that the applicants, being sisters-in-law (nanands) of Respondent No. 2, have been implicated by way of general and omnibus allegations, which is evident from a bare perusal of the First Information Report as well as the statements of the prosecution witnesses. Therefore, it is urged that the entire criminal proceedings initiated pursuant to the said First Information Report are manifestly untenable in law and deserve to be quashed. He also placed reliance on the decision of the Apex Court in the case of Kahkashan Kausar & Ors.

vs. State of Bihar [(2022) 6 SCC 599).

5. Learned counsel for the State has vehemently opposed the prayer made in the present petition and submitted that specific and direct allegations have been levelled against the applicants in the FIR. It is contended that the present applicants subjected respondent No. 2 to cruelty and harassment in connection with unlawful demand of dowry, which is clearly established from the contents of the FIR. On the strength of the aforesaid submissions, learned counsel submits that the present petition deserves to be dismissed.

6. No other point is pressed or argued by the parties.

7. Heard the submissions of learned counsel for the parties and perused the record.

8. A perusal of the record reveals that respondent No. 2 lodged the FIR alleging that, soon after the marriage, the present applicants raised an unlawful demand for a c

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