The Supreme Court quashed criminal proceedings under Sections 498A/34 IPC and Sections 3/4 of the Dowry Prohibition Act against the father-in-law, invoking Article 142 of the Constitution. The Court held that continuing prosecution after divorce and in the absence of specific, timely allegations amounted to an abuse of the process of law.
Facts Of The Case:
The marriage between the complainant (Respondent No. 2) and the appellant’s son was solemnized in December 2017. By May 2019, marital discord arose, leading the wife to leave the matrimonial home and allege mental and physical cruelty. Both parties attended police-led counselling sessions, which resulted in an agreement to remarry through Hindu rites. However, the wife soon left again and, in July 2019, filed an FIR alleging that her father-in-law (the appellant) had slapped her at a railway station, publicly admonished her, and made repeated demands for dowry, including cash and valuables. The appellant, along with other family members, sought to quash the FIR under Section 482 of the CrPC. The High Court quashed proceedings against the mother-in-law and sister-in-law due to a lack of specific allegations but allowed the case to continue against the appellant and his son. Subsequently, a divorce decree was granted between the husband and wife in August 2021, which had attained finality, prompting the father-in-law’s appeal to the Supreme Court.
Procedural History:
The procedural history began with the registration of FIR No. 58 of 2019 at Mahila Police Station, Jabalpur, against the appellant and his family. Following the filing of a chargesheet, the appellant approached the Madhya Pradesh High Court under Section 482 of the CrPC seeking quashing of the FIR and all consequential proceedings. In a common order dated May 7, 2024, the High Court partly allowed the petitions; it quashed the proceedings against the mother-in-law and sister-in-law for lacking specific allegations but refused to quash those against the appellant and his son. Aggrieved by this decision, the appellant (the father-in-law) filed a Special Leave Petition before the Supreme Court, which granted leave and culminated in the present criminal appeal.
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Court Observation:
The Court observed that the FIR was highly belated, as the alleged incident of slapping and dowry demand occurred in June 2019 but was reported only in July 2019 after the wife received summons in divorce proceedings initiated by the husband. It noted the absence of any complaint regarding these serious allegations during the contemporaneous police counselling sessions, which instead culminated in a mutual agreement to reconcile. The Court further emphasized that with the marital relationship having been legally dissolved by a divorce decree that attained finality, the continuation of criminal proceedings against the father-in-law, emanating solely from the erstwhile matrimonial discord, would serve no useful purpose and would amount to an abuse of the process of law.
Final Decision & Judgement:
The Supreme Court allowed the appeal and set aside the impugned order of the High Court. Invoking its extraordinary powers under Article 142 of the Constitution of India to do complete justice, the Court quashed FIR No. 58 of 2019 and the consequent charge sheet, thereby terminating all criminal proceedings against the appellant. The judgement held that continuing the prosecution after the divorce and in the absence of compelling, timely allegations would perpetuate hostility and amount to an abuse of the legal process.
Case Details:
Case Title: Mange Ram vs. State of Madhya Pradesh & Anr. Citation: 2025 INSC 962 Criminal Appeal No.: (Arising out of SLP (Crl.) No. 10817 of 2024) Date of Judgement: August 12, 2025 Judges/Justice Name: Justice B.V. Nagarathna and Justice K.V. Viswanathan
Download The Judgement Here