Cruelty and harassment - FIR quashed where allegations were vague and general, lacking specific particulars
Supreme Court Quashes FIR Against In-Laws in Dowry and Cruelty Case. Allegations deemed vague and general; proceedings against the husband to continue separately
In a significant judgment delivered on September 26, 2025, the Supreme Court of India has quashed the FIR against the appellants, who are the father-in-law, mother-in-law, and sister-in-law of the complainant, in the case alleging cruelty and harassment under Sections 498-A, 377, and 506 of the Indian Penal Code. The apex court held that the allegations in the FIR were vague and lacked specific particulars necessary to constitute a prima facie case against the appellants.
The proceedings originated from a complaint filed by the complainant, alleging demands for dowry and gifts by her in-laws and mental torture by her husband. The FIR was initially registered under Section 498-A, with subsequent additions of Sections 377 and 506. While the High Court of Judicature at Bombay had dismissed the appellants' plea to quash the FIR, the Supreme Court, upon review, found that the allegations were generalized and did not meet the statutory requirements for the offenses charged.
The bench comprising Chief Justice B.R. Gavai, Justice K. Vinod Chandran, and Justice Atul S. Chandurkar emphasized that the continuation of proceedings against the appellants would be an abuse of the process of law. The judgment underscored the principle that vague and omnibus allegations without specific details cannot justify the continuation of criminal proceedings.
The court clarified that the allegations concerning unnatural sex and criminal intimidation under Sections 377 and 506 were directed solely against the complainant's husband, and there was no basis for implicating the appellants in these charges. Consequently, the proceedings against the husband will continue to be adjudicated independently on their merits.
This ruling aligns with established legal precedents, particularly referencing the principles laid down in the landmark case of State of Haryana v. Bhajan Lal, which guides the quashing of FIRs when allegations do not constitute a prima facie case. The judgment brings relief to the appellants, ensuring their exclusion from criminal proceedings that were deemed unjustified, while maintaining the course of action against the complainant's husband.
Statutory provision(s): Sections 498-A, 377, 506 IPC, Section 34 IPC, Section 482 CrPC
Sanjay D. Jain v. State of Maharashtra, (SC) : Law Finder Doc id # 2784425
