Delhi High Court Quashes FIR in Dowry Harassment Case
Allegations Found Vague and Unsupported by Evidence; Court Declares Abuse of Legal Process
In a significant judgment delivered on October 8, 2025, the Delhi High Court, presided by Justice Ms. Neena Bansal Krishna, quashed the FIR filed under Sections 498A, 406, and 34 of the Indian Penal Code (IPC), in a case alleging dowry harassment and cruelty. The case, titled "Smt. Karuna Sejpal Gupta v. State (Govt. of NCT Delhi)," involved allegations by the complainant, Respondent No. 2, against her deceased husband's family, claiming harassment and cruelty related to dowry demands.
The FIR was registered on June 18, 2016, following the complainant's allegations that her deceased husband and his family had subjected her to mental torture over dowry demands, eventually leading to her husband's suicide on April 13, 2016, in Pune, Maharashtra, just 40 days after their marriage. However, the court found that the allegations were vague, contradictory, and not corroborated by any substantial evidence, including WhatsApp chats provided by the complainant.
Justice Krishna meticulously analyzed the evidence and the circumstances surrounding the case. The court noted that the allegations against the petitioners, including demands for money and gold ornaments, were not supported by any bank statements or evidence indicating such demands were made. Furthermore, the WhatsApp chats presented did not reveal any harassment or dowry demands.
The judgment emphasized the importance of precise and corroborative evidence in cases under Section 498A IPC, which deals with cruelty towards a woman by her husband or his relatives. The court stated that mere assertions of cruelty without substantive evidence do not suffice to constitute an offense under this section.
Addressing the issue of territorial jurisdiction, the court held that the Delhi Courts had jurisdiction over the matter, as the complainant was residing in Delhi and the effects of the alleged cruelty were felt there. This decision aligns with precedents set by the Supreme Court, indicating that matrimonial offenses can be tried where the consequences of cruelty ensue.
Ultimately, the court concluded that the FIR and the subsequent chargesheet represented an abuse of the legal process, warranting quashing to prevent injustice. The judgment underscored the necessity of protecting individuals from frivolous litigation based on vague and unsubstantiated claims.
This decision reflects the judiciary's commitment to ensuring justice by critically evaluating evidence and preventing the misuse of legal provisions designed to protect individuals from genuine harm.
Bottom Line:
FIR alleging offences under Sections 498A/406/34 IPC quashed as allegations of cruelty and harassment for dowry were found vague, uncorroborated, and unsupported by cogent evidence.
Statutory provision(s): Sections 482, 177, 178, 179 of CrPC, 1973; Sections 498A, 406, 34 of IPC
Smt. Karuna Sejpal Gupta v. State (Govt. of NCT Delhi), (Delhi) : Law Finder Doc Id # 2791066
