IN THE HIGH COURT OF MADHYA PRADESH AT JABALPUR BEFORE HON'BLE SHRI JUSTICE B. P. SHARMA ON THE 12^th OF DECEMBER, 2025 WRIT PETITION No. 25715 of 2025 MAYUR MISHRA AND OTHERS Versus THE STATE OF MADHYA PRADESH AND OTHERS Appearance:

Shri Priyank Agrawal – Advocate for the petitioners.

Shri A.N. Gupta – Govt. Advocate for respondent/State.

Shri Devansh Verma – Advocate for respondent No.3.

ORDER

The present writ petition has been filed by the petitioners under Article

226 of the Constitution of India invoking the extraordinary jurisdiction of this Court, seeking quashment of FIR No. 662/2024 dated 20.10.2024 registered at Police Station Berasia, District Bhopal, for the offences punishable under Sections 498-A, 323 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. The grievance of the petitioners is that the impugned FIR has been lodged in the backdrop of a purely matrimonial discord, contains vague, omnibus and exaggerated allegations, and reflects a clear misuse of the criminal process with an oblique motive to harass not only the husband but also his aged parents and other close relatives, despite the absence of any specific role or overt act attributable to them.

2. It is the case of the petitioners that petitioner No.1 and respondent No.3 were married on 25.11.2020 according to Hindu rites and customs. After marriage, petitioner No.1, owing to his professional engagements, was employed at different places including Chandigarh, Bengaluru and Jaipur, and respondent No.3 resided with him. During the said period during the period when the couple resided together at Chandigarh, Bengaluru and Jaipur, no complaint alleging cruelty, harassment or dowry demand was made by respondent No.3 before any authority. According to the petitioners, matrimonial relations deteriorated only at a later stage when petitioner No.1 accepted employment in Madhya Pradesh and respondent No.3 expressed her unwillingness to reside there.

3. On 20.05.2024, respondent No.3 submitted a written complaint to the Station House Officer, Police Station Berasia, District Bhopal, alleging cruelty and dowry demand against petitioner No.1 and his family members. Since no FIR was registered on the said complaint, respondent No.3 thereafter approached the Court of JMFC, Berasia by filing a private complaint under Section 175(3) of the BNSS, 2023.

4. Pursuant to the order passed by the JMFC, Berasia, an enquiry was conducted by Police Station Berasia. After recording statements of the parties, a report dated 10.08.2024 was submitted before the Magistrate. In the said enquiry report, it was recorded that no offence relating to dowry demand or cruelty was found to be made out and that the dispute appeared to be matrimonial in nature.

5. Despite the aforesaid enquiry report dated 10.08.2024, FIR No. 662/2024 came to be registered on 20.10.2024 at Police Station Berasia, District Bhopal, for the offences punishable under Sections 498-A, 323 and 34 of the Indian Penal Code, 1860 and Sections 3 and 4 of the Dowry Prohibition Act, 1961 against petitioner No.1, his parents (petitioner Nos.2 and 3) and his paternal uncles (petitioner Nos.4 and 5). The FIR was lodged based on the same facts that had been previously denied by the Berasia police. In the impugned FIR, respondent No.3 alleged that after a few months of marriage, the petitioners demanded an amount of Rs.20,00,000/- and a Scorpio vehicle as additional dowry and that on non-fulfilment of the said demand she was subjected to physical and mental cruelty. It was further alleged that on 01.10.2023 she was forcibly turned out of the matrimonial home by the petitioners.

6. The petitioners have pleaded that petitioner Nos.2 and 3 are aged parents of petitioner No.1, permanently residing in their ancestral village Parasi, District Vidisha, for several decades. It is further pleaded that petitioner Nos.4 and 5 are paternal uncles of