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

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ON THE 18 OF FEBRUARY, 2026 MISC. CRIMINAL CASE No. 9003 of 2025 RAVI SINGH SAKHWAR (GEHLOT)

Versus THE STATE OF MADHYA PRADESH AND OTHERS Appearance:

Shri Pramod Kumar Pachori - Advocate for the petitioner.

Shri Satendra Singh Sikarwar - PP for the State.

None for respondent No.2/ complainant, though served.

ORDER

1. The present petition has been filed under Section 482 of the Code of Criminal Procedure seeking quashment of FIR bearing Crime No. 543/2023 registered at Police Station Ambah, District Morena for offences punishable under Sections 498-A, 323, 294, 506, 34 of the IPC and Sections 3/4 of the Dowry Prohibition Act, along with all consequential proceedings including RCT No. 17/2024 pending before the competent Court.

2. As per the prosecution case, the complainant Rekha Devi lodged a written complaint alleging demand of dowry in the form of a motorcycle and Rs. 50,000/- by her husband and in-laws. It is specifically alleged that upon refusal, she was subjected to physical assault, abuse and criminal intimidation, and ultimately left at her parental home with threats that she would not be taken back unless the demanded dowry was fulfilled. After investigation, statements under Section 161 Cr.P.C. were recorded, spot map prepared, and upon finding prima facie material, charge-sheet was filed against the accused persons including the present petitioner (brother-in-law).

3. The petitioner has primarily contended that the petitioner has been falsely implicated and is living separately. He is a student preparing for competitive examinations. FIR is fabricated. The police failed to comply with the directions issued in Rajesh Sharma v. State of Uttar Pradesh, (2017) SCC Online 821 . His name has been included arbitrarily without specific allegations. Continuation of proceedings would prejudice his future. Only omnibus allegations have been levelled against the petitioner. He is a very laborious and studious person. He is also meritorious. No specific role or date of alleged incident has been mentioned. Even, he lives separately and a rent agreement has also been produced before this Court. Now-a-days, it is a general tendency to falsely implicate all the family members of in-laws just to exert undue pressure. The whole carrier of the petitioner is at stake. Hence, the present petition may be allowed and the aforementioned FIR may be quashed.

4. Learned counsel for the respondent/State opposed the prayer and prayed for its rejection.

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

6. The law relating to quashing of FIR is well settled. In State of Haryana v. Bhajan Lal,1992 Supp (1) SCC 335, the Hon’ble Supreme Court laid down illustrative categories where quashing may be permissible.

However, it was simultaneously cautioned that the power is to be exercised sparingly and in rarest of rare cases. The principles were reiterated in Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra (2021) 19 SCC 401, wherein the Supreme Court held that at the stage of investigation or charge-sheet, the Court cannot conduct a mini-trial and FIR must be read as a whole. If prima facie offence is disclosed, proceedings should not be quashed. Defence of the accused cannot be considered at this stage. Further, in R.P. Kapur v. State of Punjab AIR 1960 SC 866, the Supreme Court clarified that inherent jurisdiction cannot be invoked where allegations prima facie constitute an offence. Thus, the jurisdiction under Section 482 Cr.P.C.

is not meant to assess the reliability or sufficiency of evidence.

7. In the present case, the petitioner is named in the FIR. Allegations of dowry demand and harassment are attributed to all accused collectively. The FIR also narrates continuous harassment and specific date of assault i.e.

20/05/2023.

8. The petitioner has relied upon a rent agreement dated 21.01.2025 to establish separate residence