Supreme Court Quashes FIR in Dowry Harassment Case, Cites Lack of Concrete Evidence
Suprreme Court warns against misuse of legal provisions in matrimonial disputes, emphasizes need for specific allegations supported by evidence.
In a significant ruling, the Supreme Court of India has quashed an FIR filed against Shobhit Kumar Mittal and his family members in a dowry harassment case, emphasizing the lack of specific allegations and concrete evidence. The bench, comprising Justices B.V. Nagarathna and R. Mahadevan, delivered the judgment on September 24, 2025, setting aside the order of the Allahabad High Court which had refused to quash the proceedings.
The case originated from an FIR lodged by Smt. Jyoti Garg against her husband, Mohit Mittal, her mother-in-law, and her brother-in-law, Shobhit Kumar Mittal, under Sections 323 and 498A of the Indian Penal Code and Sections 3 and 4 of the Dowry Prohibition Act. The complainant alleged harassment and cruelty for dowry, claiming that the harassment led to a medical condition resulting in paralysis.
However, the Supreme Court found the allegations in the FIR to be vague, lacking specific details such as the time, date, and manner of the alleged harassment. The Court stressed that mere general allegations without precise incidents weaken the prosecution's case and could potentially lead to a miscarriage of justice.
The bench cited the guidelines from the landmark judgment in State of Haryana v. Bhajan Lal, which outlines scenarios where the court may quash an FIR to prevent abuse of legal processes. The Court noted that the allegations were inherently improbable and unsupported by any tangible evidence, thus failing to fulfill the ingredients required under the alleged offences.
Emphasizing the need for caution in matrimonial disputes, the Supreme Court highlighted the increasing misuse of Section 498A IPC, cautioning against prosecuting family members without specific evidence. The judgment also referenced another recent decision in Dara Lakshmi Narayana v. State of Bihar, stressing the importance of preventing the misuse of legal provisions as a tool for personal vendetta.
The Court's decision underscores the judiciary's commitment to safeguarding individuals from unwarranted legal harassment while maintaining the integrity of genuine complaints of cruelty and harassment in matrimonial contexts.
Bottom Line:
FIR containing vague and omnibus allegations without specific details or concrete evidence cannot form the basis for criminal prosecution. Courts must exercise caution in matrimonial disputes to prevent misuse of legal provisions and harassment of innocent family members.
Statutory provision(s): Indian Penal Code, 1860 Sections 323 and 498A; Dowry Prohibition Act, 1961 Sections 3 and 4; Criminal Procedure Code, 1973 Section 482.
Shobhit Kumar Mittal v. State of Uttar Pradesh, (SC) : Law Finder Doc Id # 2783362
