Madhya Pradesh High Court
Rahul Singh vs The State Of Madhya Pradesh on 13 October, 2025
Author: Milind Ramesh Phadke
Bench: Milind Ramesh Phadke
NEUTRAL CITATION NO. 2025:MPHC-GWL:25775
1 MCRC-46173-2023
IN THE HIGH COURT OF MADHYA PRADESH
AT GWALIOR
BEFORE
HON'BLE SHRI JUSTICE MILIND RAMESH PHADKE
ON THE 13th OF OCTOBER, 2025
MISC. CRIMINAL CASE No. 46173 of 2023
RAHUL SINGH
Versus
THE STATE OF MADHYA PRADESH AND OTHERS
Appearance:
Shri Gaurav Mishra - Advocate for the applicant.
Shri Dinesh Savita - Public Prosecutor for the State.
Shri Upendra Yadav - Advocate for the respondent No.2.
ORDER
The present application under Section 482 of Cr.P.C is filed for
quashment of FIR and entire criminal proceedings arising out of the Crime
No.50/2022 registered at Police Station Morar, District Gwalior for the
offence punishable under Sections 498-A, 323, 506 and 34 of IPC read with
Section 3/4 of of Dowry Prohibition Act.
As per prosecution story, respondent No.2/complainant Vandana
Gurjar reported to Police Station - Morar, District Gwalior on 23.01.2022 to
the effect that she was married to Rahul Gurjar on 19.05.2015 as per Hindu
rites and rituals. Her father had given Rupees One Crore in cash and 50 Tola
of Gold along with other household articles in dowry at the time of her
marriage. But after marriage, her husband Rahul, Father-in-law Radhakrishna
Gurjar, Mother-in-law Vidya Devi and Brother-in-law Ashish started
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demanding Fortuner vehicle and a house. They manhandled her many times,
due to which, she suffered spinal injury. The accused threatened to kill her, if
she reports. On such allegations, Police Station - Morar, District-
Gwalior registered alleged FIR bearing Crime No.50/2022 for offence
punishable under Sections 498-A, 323, 506, 34 of IPC and Section 3/4 of of
Dowry Prohibition Act, 1961.
Learned counsel for the applicant submits that the impugned FIR and
all consequential criminal proceedings initiated against the petitioner are
wholly false, maliciously motivated, and lodged with the sole purpose of
harassing and pressurizing the petitioner. The allegations made in the FIR are
entirely fabricated and are devoid of any specific role attributed to the
petitioner, as the FIR is clearly an abuse of the criminal justice process and is
liable to be quashed in the exercise of this Court's inherent powers under
Section 482 Cr.P.C.
It is further submitted that the complainant herself has behaved
aggressively and subjected the petitioners to cruelty, which is evident from
the photographs annexed with the application. These photographs depict the
violent and quarrelsome conduct of the complainant towards the petitioner
and family members. It is further submitted that a matrimonial dispute is
already pending between the complainant and the applicant under Section
13(A) of the Hindu Marriage Act, seeking a decree of divorce. The present
FIR has been lodged as a counterblast to these proceedings, solely with the
ulterior motive of exerting pressure and settling personal scores. The
complainant's history of quarrelsome and aggressive behavior towards her
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in-laws is further demonstrated by a prior complaint dated 27.12.2018.
It is further submitted that the continuance of other litigations between
the parties, including proceedings for maintenance and divorce pending
before the learned Principal Judge, Family Court, Gwalior, further illustrates
that the FIR is an afterthought and has been filed with malafide intentions.
The complainant's aggressive conduct and history of misbehavior, as
documented through photographs and prior complaints, establishes that the
FIR is motivated by personal vengeance and not bona fide concern.
While placing reliance on the judgment of the Hon'ble Supreme Court
in the matter of Preeti Gupta & Another vs. State of Jharkhand & Another,
(2010) 7 SCC 667, it was submitted that that most complaints under Section
498-A IPC are filed in the heat of the moment over trivial issues and are not
bona fide , often filed with oblique motives.
While placing reliance on the judgment of the Hon'ble Supreme Court
in the matter Satish Mehra vs. State (NCT of Delhi), AIR 2013 SC 506, as
well as the judgment of this Court in the matter of Ravikant Dubey & Others
vs. State of M.P., 2014 (2) MPHT 449, it was submitted that where the
allegations in an FIR, even if taken at face value, do not disclose a prima
facie offence, the accused should not be compelled to undergo the rigours of
a criminal trial. In the matter of State of Haryana vs. Bhajan Lal, 1992 Supp
(1) SCC 335, the Hon'ble Supreme Court has laid down well-recognized
parameters for the exercise of inherent powers under Section 482 Cr.P.C.,
holding that proceedings may be quashed where allegations are absurd,
inherently improbable, or instituted with malafide intent to wreak vengeance.
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Similarly, in the matter of Arnesh Kumar vs. State of Bihar, (2014) 8 SCC
273, the Apex Court cautioned against mechanical or indiscriminate
prosecution under Section 498-A IPC and emphasized judicial scrutiny
before permitting such proceedings to continue.
In light of the above, it is evident that the present FIR is a counterblast
to matrimonial litigation, filed with malafide intent and an ulterior motive to
pressurize the applicant. The allegations are vague, general, and unsupported
by material evidence. They do not constitute a prima facie offence against
the applicant, and the continuation of proceedings would amount to an abuse
of the process of law, causing undue harassment and mental agony.
Apart from the aforesaid submissions, it is also submitted that earlier
the applicant's father, mother and brother had preferred an application for
quashing of instant FIR, which was registered as MCRC 30505/2022. This
Court, vide order dated 12.09.2023, was pleased to quash the FIR in relation
to them. The present case of the applicnat stands on parity with those of his
family members.
In view of the foregoing submissons, it is prayed that the impugned
FIR and all consequential proceedings arising therefrom be quashed.
Per contra, learned counsel for the State as well as the counsel for the
complainant submits that the impugned FIR involves cognizable and non-
compoundable offences under Section 498-A IPC and other provisions,
relating to serious allegations of cruelty and harassment. FIRs in cases of
matrimonial discord should not be lightly interfered with, and the inherent
powers of this Court under Section 482 Cr.P.C. are to be exercised only in
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exceptional cases where allegations are absurd or malafide. The existence of
ongoing matrimonial proceedings does not invalidate the FIR or make it a
counterblast. The complainant is entitled to seek protection under criminal
law, and the allegations warrant proper investigation. The applicant has not
produced any material to show that the FIR is fabricated or frivolous. In
view of the above, it is submitted that the quashing application is not
maintainable, and the FIR should be allowed to proceed, with the police
directed to complete the investigation expeditiously.
Heard counsel for the parties and perused the record.
It is evident from the material on record, including prior complaints
lodged by the applicant's family members, photographs, CCTV footage, and
the pendency of matrimonial proceedings under Section 13(A) of the Hindu
Marriage Act, that the FIR has been filed as a counterblast to ongoing family
disputes, rather than as a bona fide criminal complaint.
It is settled law that the inherent powers of this Court under Section
482 Cr.P.C. can be exercised to prevent abuse of the process of law and to
secure the ends of justice. The Hon'ble Supreme Court in State of Haryana
vs. Bhajan Lal, 1992 Supp (1) SCC 335 had laid down that FIRs may be
quashed where allegations are absurd, inherently improbable, or instituted
with malafide intent. Similarly, in Preeti Gupta & Another vs. State of
Jharkhand & Another, (supra), it was observed that complaints under Section
498-A IPC are often filed with oblique motives and not bona fide . Arnesh
Kumar vs. State of Bihar, (supra) cautions against mechanical prosecutions
under Section 498-A IPC and emphasizes judicial scrutiny before allowing
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such proceedings to continue.
In the present case, the allegations in the FIR are vague, general, and
unsupported by material evidence. The applicant has shown that the
complainant has previously committed acts of aggression towards the
applicant's elderly parents, and at prior point of time, FIRs against them had
already been quashed by this Court (MCRC 30505/2022), demonstrating
parity in circumstances., thus, continuation of the present FIR would cause
undue harassment and mental agony to the applicant and would constitute an
abuse of the process of law.
Accordingly, the application filed by the applicant Rahul Singh under
Section 482 Cr.P.C. is hereby allowed, and the FIR bearing Crime No.
50/2022 registered at Police Station - Morar, District- Gwalior for the
offence punishable under Sections 498-A, 323, 506 and 34 of IPC read with
Section 3/4 of of Dowry Prohibition Act, 1961 and all consequential
proceedings thereto against him are hereby quashed.
No order as to costs.
(MILIND RAMESH PHADKE)
JUDGE
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