In a significant ruling, the Supreme Court of India quashed criminal proceedings against a father-in-law accused of dowry harassment and cruelty under Sections 498A, 34 IPC and Sections 3 & 4 of the Dowry Prohibition Act, observing that the FIR appeared “belated and motivated” after the dissolution of marriage. The judgment, delivered by a bench comprising Justice B.V. Nagarathna and Justice K.V. Viswanathan, emphasized that continuing prosecution in matrimonial disputes after divorce serves “no useful purpose” and would only perpetuate hostility.
The case (Mange Ram vs. State of Madhya Pradesh & Anr., 2025 INSC 962) arose from an FIR registered in 2019 by a woman (Respondent No. 2) alleging that her husband, father-in-law (appellant), mother-in-law, and sister-in-law had subjected her to mental and physical cruelty and demanded dowry, including Rs. 5 lakhs in cash, gold ornaments, and a car. The marriage, solemnized in 2017 under the Special Marriage Act, turned sour by 2019, leading to separation.
The complainant alleged that during a counselling session at Mahila Police Station, Jabalpur, her father-in-law slapped her at the railway station and threatened her. However, the FIR was filed only in July 2019, nearly two months after the alleged incident, and after her husband had initiated divorce proceedings.
Key Observations of the Supreme Court
The Court noted that the delay in lodging the FIR and the absence of any immediate complaint during counselling cast doubt on the allegations. “If such an incident had occurred, the complainant would have raised it during counselling,” the bench remarked.
The Court highlighted that since the divorce decree (August 2021) had attained finality, continuing criminal proceedings against the father-in-law would be “an abuse of the process of law.”
The bench referred to its earlier judgment in Dara Lakshmi Narayana vs. State of Telangana (2025), observing that “family members should not be roped in unnecessarily in matrimonial disputes.”
Citing Gian Singh vs. State of Punjab (2012) and Naushey Ali vs. State of UP (2025), the Court held that quashing such cases promotes reconciliation and prevents misuse of criminal law.
The Supreme Court set aside the Madhya Pradesh High Court’s order that had refused to quash proceedings against the father-in-law. It invoked Article 142 to ensure complete justice, thereby quashing the FIR and all subsequent proceedings against the appellant.
This judgment reinforces the judiciary’s stance against misuse of anti-dowry laws while balancing the rights of victims and accused in matrimonial disputes. Legal experts believe this ruling will set a precedent for similar cases where criminal proceedings persist even after marital ties are legally severed.
Sections 498A Explained
Section 498A of the Indian Penal Code (IPC) addresses cruelty against a married woman by her husband or his relatives. It defines cruelty and prescribes punishment for those who subject a woman to it. The law aims to protect women from harassment and torture within the marital home. Offenses under Section 498A are cognizable (police can arrest without a warrant) and non-bailable (bail can be denied). A complaint can be filed by the woman herself, her relatives, or a public servant if no relatives are available.
There have been concerns about the misuse of Section 498A, with some cases being filed to settle personal scores rather than for genuine instances of cruelty. Studies have shown.
The Supreme Court has issued guidelines to prevent the misuse of Section 498A, emphasizing the need for thorough investigations and cautioning against unnecessary arrests. In simpler terms: Section 498A makes it a crime for a husband or his family to be cruel to a married woman, with consequences like jail time and fines. It’s meant to protect women but has faced misuse concerns, leading to Supreme Court guidelines.