The Supreme Court held that the High Court erred in quashing criminal proceedings under Section 482 CrPC by conducting a “mini-trial” on the credibility of allegations. The power to quash an FIR is to be exercised sparingly and only when allegations, taken at face value, disclose no cognizable offence. The existence of prima facie allegations necessitates permitting the investigation to proceed.
Facts Of The Case:
The appellant, Muskan, married respondent No. 1, Ishaan Khan, on 20.11.2020. After five to six months of marriage, she alleged that her husband and his family (respondents 1 to 5) began harassing and taunting her for insufficient dowry. Specific incidents included being slapped by her brother-in-law on 22.07.2021 and, on 27.11.2022, her husband demanding Rs. 50 lakhs from her father for his medical studies, threatening to abandon her otherwise, and subsequently ousting her and their son from the matrimonial home. The appellant filed complaints with the Women’s Cell in Ratlam on 22.01.2023 and 23.01.2023, alleging general harassment and dowry demands. Subsequently, an FIR (No. 35 of 2024) was registered on 28.01.2024 under Section 498A IPC and Sections 3 & 4 of the Dowry Prohibition Act, 1961, detailing the specific incidents of 2021 and 2022. The respondents filed a petition under Section 482 CrPC before the High Court, which quashed the FIR, noting that the two specific incidents were not mentioned in the earlier complaints and were therefore an “afterthought.” The appellant challenged this order before the Supreme Court.
Procedural History:
The procedural history of the case began with the registration of FIR No. 35 of 2024 against the private respondents (husband and in-laws) under Section 498A IPC and Sections 3 & 4 of the Dowry Prohibition Act, 1961. The respondents then filed Miscellaneous Criminal Case No. 10695 of 2024 before the High Court of Madhya Pradesh at Indore under Section 482 of the Code of Criminal Procedure, 1973, seeking quashing of the FIR. The High Court, vide its order dated 19.07.2024, allowed the petition and quashed the proceedings. Aggrieved by this order, the appellant (wife) filed a Special Leave Petition (Criminal) No. 1531 of 2025 before the Supreme Court of India. The Supreme Court granted leave, issued notice, and after hearing the parties, allowed the Criminal Appeal No. 4752 of 2025, setting aside the High Court’s impugned order and restoring the criminal proceedings.