SC Quashes Dowry Harassment Case Against Father-in-law

Introduction:
In a recent judgment, the Supreme Court in Special Leave Petition (Criminal) No. 10817 of 2024, dated 12 August 2025, quashed criminal proceedings against a father-in-law accused under Section 498A of the Indian Penal Code (IPC) and Sections 3 and 4 of the Dowry Prohibition Act, 1961. The Court invoked its extraordinary powers under Article 142 of the Constitution to “do complete justice,” holding that continuation of criminal proceedings after the dissolution of marriage between the principal parties would serve no meaningful purpose.

Background of the Case in a Nutshell:
The complainant (respondent no. 2) married the appellant’s son on 23 December 2017 under the Special Marriage Act. Within two years, marital discord arose. The complainant alleged mental and physical cruelty, dowry demands, and even physical assault by her husband and his family. On 21 July 2019, she lodged FIR No. 58/2019 at Mahila Police Station, Jabalpur, accusing her husband, father-in-law (the appellant), mother-in-law, and sister-in-law under Sections 498A, 34 IPC, and Sections 3 and 4 of the Dowry Prohibition Act. The High Court, in May 2024, quashed proceedings against the mother-in-law and sister-in-law but refused similar relief to the husband and father-in-law, citing specific allegations against them. Aggrieved, the father-in-law approached the Supreme Court.

Observations of the Supreme Court:

1. Delay and Lack of Specificity in Allegations: The Court noted that the alleged incident of assault and dowry demand was said to have occurred on 2 June 2019 during counseling sessions. However, no contemporaneous complaint was made at the time. Instead, the FIR was lodged nearly two months later, after the husband had initiated divorce proceedings, raising serious doubts about the credibility of the allegations.
   
   

2. Divorce and Futility of Criminal Proceedings: A decree of divorce had already been granted by a Family Court on 24 August 2021, which had attained finality. Once the marriage legally ended, the Court observed, further prosecution of the father-in-law would “neither advance the cause of justice nor serve any practical purpose” but would only perpetuate hostility.
   
   

3. Misuse of Section 498A: Relying on Dara Lakshmi Narayana v. State of Telangana (2025), the Court reiterated that there is a growing tendency to implicate all family members in matrimonial disputes. Courts must guard against misuse of criminal law to harass relatives without specific evidence.
   
   

Invoking Jurisdiction under Article 142 of the Constitution:
The Court relied on earlier rulings including Mala Kar v. State of Uttarakhand (2024), Arun Jain v. State of NCT of Delhi (2024), and Gian Singh v. State of Punjab (2012), holding that matrimonial disputes, once resolved by divorce or settlement, may be quashed under Article 142 to avoid abuse of process. The Court stressed that its duty is to balance redress for genuine grievances with the need to prevent misuse of criminal law. By invoking Article 142, the Supreme Court set aside the Madhya Pradesh High Court’s order refusing to quash proceedings and quashed FIR No. 58/2019 and the charge sheet dated 18 August 2019 against the appellant (father-in-law).

Importance of the Judgment:

• Safeguards Against Misuse of Section 498A IPC: The Court highlighted the need to protect relatives from frivolous or exaggerated allegations in matrimonial disputes. This decision underscores how the Supreme Court can step in to quash criminal proceedings that have lost relevance after divorce, even if the offences are technically non-compoundable.
  
  

Conclusion:
The ruling reflects a pragmatic and humane approach by the Supreme Court. By quashing proceedings against the father-in-law, the Court emphasized that criminal law must not be wielded as a weapon of vengeance once a marriage has broken down and both parties have moved on. The judgment will likely serve as an important precedent in dowry and matrimonial litigation, reinforcing the principle that justice must balance accountability with fairness.

*****By Mahesh Tiwari, Advocate, Supreme Court of India