The Supreme Court quashed the FIR under Section 498-A, 377, and 506 read with Section 34 IPC against the in-laws. It held that general and vague allegations, without specific details of cruelty or unlawful demands, do not constitute a prima facie case. The Court reiterated that proceedings without such foundational ingredients amount to an abuse of the process of law.
Facts Of The Case:
The appellants, who were the father-in-law, mother-in-law, and sister-in-law of the complainant, sought the quashing of an FIR registered against them. The FIR alleged offences under Sections 498-A (cruelty), 377 (unnatural sex), and 506 (criminal intimidation) read with Section 34 (common intention) of the Indian Penal Code. The marriage between the complainant and the appellants’ son/brother took place in July 2021. The core of the complainant’s allegations was that the appellants continuously demanded gifts and dowry from her and her family. A specific instance was cited where the mother-in-law demanded clothes and jewellery. The complainant also alleged that her husband subjected her to unnatural sex, causing mental torture. After investigation, a final report was filed. The appellants approached the High Court under Section 482 of the CrPC to quash the proceedings, but their petition was dismissed, leading them to appeal before the Supreme Court.
Procedural History:
The procedural history of this case began with the registration of FIR No. 20 of 2022 for offences under Sections 498-A, 377, and 506 read with Section 34 of the IPC. Following the investigation, a final report was filed. The appellants, along with the husband, then filed an application under Section 482 of the Code of Criminal Procedure, 1973, before the High Court of Judicature at Bombay, Nagpur Bench, seeking quashing of the criminal proceedings. The High Court, vide its order dated 19.03.2024 in Criminal Application No. 741 of 2022, dismissed the application, finding prima facie material to proceed with the trial. Aggrieved by this dismissal, the appellants (excluding the husband) filed a Special Leave Petition (Crl.) No. 12584 of 2024 before the Supreme Court, which granted leave and culminated in the present criminal appeal.
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Court Observation:
The Supreme Court observed that the allegations in the FIR against the appellant in-laws were general, vague, and devoid of specific particulars. It held that for an offence under Section 498-A IPC, the cruelty must be of a nature that is likely to drive a woman to suicide or cause grave injury, or involve harassment for unlawful dowry demands, which was not made out from a complete reading of the complaint. Regarding the offences under Sections 377 and 506 IPC, the Court noted that the specific allegations were directed solely against the husband, with no averments whatsoever implicating the appellants. Consequently, the Court found that no prima facie case was established against the appellants, and allowing the proceedings to continue against them would amount to an abuse of the process of law.
Final Decision & Judgement:
The Supreme Court allowed the appeal and quashed the criminal proceedings arising from FIR No. 20 of 2022, along with the subsequent final report, against the appellant in-laws for the offences under Sections 498-A, 377, and 506 read with Section 34 of the Indian Penal Code. The Court held that continuing the prosecution against them in the absence of specific allegations constituting a prima facie case would be an abuse of the process of law. It was clarified that this judgement is restricted to the appellants and shall not impede the ongoing proceedings against the husband (accused No. 1), which are to be adjudicated on their own merits.
Case Details:
Case Title: Sanjay D. Jain & Ors. versus State of Maharashtra & Ors. Citation: 2025 INSC 1168 Criminal Appeal No.: (Arising out of Special Leave Petition (Crl.) No. 12584 of 2024) Date of Judgement: September 26, 2025 Judges/Justice Name: Justice B.R. Gavai & Justice K. Vinod Chandran & Justice Atul S. Chandurkar
Download The Judgement Here