Recently, the Supreme Court held that criminal proceedings against a husband’s relatives cannot continue on the basis of vague and omnibus allegations lacking specific overt acts, while quashing dowry harassment and domestic violence proceedings against the in-laws. The Court observed that “criminal law cannot be permitted to become an instrument for venting personal grievances or settling familial scores in the absence of clear, specific and legally sustainable allegations.”
Brief facts:
The case stemmed from matrimonial discord, which led to registration of an FIR under Sections 498A and 34 of the IPC, read with Sections 3 and 4 of the Dowry Prohibition Act, against the husband and his relatives over allegations of dowry harassment and cruelty. The complainant alleged that despite substantial dowry being given at the time of marriage, she was subjected to mental and physical harassment for additional money. She later also initiated proceedings under the Protection of Women from Domestic Violence Act, 2005, accusing the husband and his family members of abuse, intimidation, restrictions on her movement and other acts of domestic cruelty. The Madhya Pradesh High Court refused to quash the criminal and DV proceedings against the in-laws, following which the accused relatives approached the Apex Court seeking quashing of the case on the ground that the allegations against them were vague, omnibus and unsupported by specific overt acts.
Contentions of the Appellant:
The Appellant argued that they had been implicated solely because of their relationship with the husband and that the allegations in both the FIR and DV complaint were entirely omnibus, vague and unsupported by any specific overt act. It was submitted that the complainant herself had admitted in her divorce proceedings that she primarily resided with her husband in a government accommodation and not with the in-laws. The Appellants contended that the FIR was retaliatory in nature and had been lodged immediately after the husband instituted proceedings under Section 9 of the Hindu Marriage Act seeking restitution of conjugal rights. They further argued that the allegations failed to satisfy the ingredients required for prosecution under Section 498A of the IPC, the Dowry Prohibition Act or the DV Act.
Contentions of the Respondent:
On the other hand, counsel for the Respondent supported the High Court’s orders and argued that matrimonial FIRs cannot be expected to contain exhaustive details of every incident at the initial stage. The Respondent contended that allegations relating to dowry demands, mental harassment, physical abuse and expulsion from the matrimonial home raised triable issues requiring appreciation of evidence during trial. The Counsel also argued that questions regarding shared household and domestic relationships under the DV Act were disputed factual issues that could not be conclusively determined in proceedings under Section 482 of the CrPC.
Observation of the Court:
The Division Bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh observed, “What, therefore, emerges from a cumulative reading of the FIR and the divorce petition is that while there are specific allegations against the husband relating to physical assault, verbal abuse, neglect and suspicious conduct, the allegations against the present appellants remain bald, generalised, and devoid of material particulars. No independent or specific role has been attributed to any of the present appellants so as to disclose prima facie commission of offences under Sections 498A/34 IPC or Sections 3 and 4 of the Dowry Prohibition Act. The allegations against them appear to be omnibus assertions made on account of their relationship with the husband rather than on the basis of any distinct criminal acts allegedly committed by them.”
The Bench emphasised, “It is a matter of common judicial experience that matrimonial disputes are often accompanied by heightened emotions, strained relationships and deep-seated personal grievances. In such circumstances, complaints alleging cruelty and harassment frequently tend to implicate not only the spouse but also the entire family of the spouse, including those relatives who may have had little or no active role in the matrimonial discord. Quite often, family members who may have remained passive spectators, failed to intervene, or merely sided with one party in a domestic disagreement, are also arrayed as accused.”
The Court further held, “Mere familial association with the husband, or failure to support the complainant in a marital dispute, cannot by itself constitute a criminal offence in the absence of specific allegations disclosing active participation in acts amounting to cruelty, harassment or unlawful demand of dowry.” The Court clarified that, “while the anguish of a complainant in a failed marriage cannot be lightly disregarded, equally, criminal law cannot be permitted to be set in motion against every relative of the husband merely on the basis of generalised and omnibus allegations lacking a specific factual foundation.”
The Bench observed, “What ultimately emerges from a cumulative reading of the DV complaint is that while the complainant has narrated several detailed allegations concerning the husband’s conduct and the strained matrimonial relationship between the spouses, the allegations against the present appellants remain generalised and derivative in character. The complaint does not disclose any specific or direct act individually attributable to the appellants constituting domestic violence, physical abuse, verbal abuse, emotional abuse or economic abuse within the meaning of the DV Act.” The Court noted that the allegations were essentially confined to assertions that the relatives supported the husband or advised the complainant to adjust.
The Court held, “The allegations against them are essentially that they supported the husband, failed to intervene in the matrimonial dispute, or asked the complainant to adjust to the situation. Such omnibus and broadly worded allegations, in the absence of clear particulars and specific overt acts, would not justify continuation of proceedings against the present appellants.” The Bench reiterated that criminal prosecution cannot be sustained merely because the accused persons are related to the husband in a matrimonial dispute.
The decision of the Court:
The Apex Court ultimately allowed the appeals and quashed the pending criminal proceedings as well as the domestic violence proceedings against the Appellants. The Court held that prosecution in matrimonial disputes can continue only where allegations against each accused are specific, distinct and supported by prima facie material indicating active involvement in cruelty, harassment or dowry demand. The Bench clarified that vague allegations that relatives “supported” the husband or failed to intervene in the dispute are insufficient to sustain criminal prosecution under Section 498A of the IPC or the DV Act.
Case Title: Arti Mehta & Ors. Vs. The State of Madhya Pradesh & Anr.
Case No.: Special Leave Petition (Crl) No. 18345 of 2024
Citation: 2026 Latest Caselaw 421 SC
Coram: Hon’ble Mr. Justice Sanjay Karol, Hon’ble Mr. Justice Nongmeikapam Kotiswar Singh
Advocate for the Petitioner: AOR Vidhi Pankaj Thaker, Adv. Nipun Saxena, Adv. Prastut Mahesh Dalvi, Adv. Aadya Pandey, Adv. Deepali Dabas, Adv. B. D. Kundan, Adv. B.D. Kundan, Adv. Dev Nagar
Advocate for the Respondent: AOR Nishant Verma, AOR Yashraj Singh Bundela, Adv. Sankalp Sharma, Adv. Amitabh Ranjan, Adv. Samiksha Sharma, Adv. Arpit Garg
