The Madhya Pradesh High Court ruled that it is common for victims of crimes to involve all members of the accused's family as a means of settling personal grievances.

The Court emphasized that an FIR should not be treated as an exhaustive account of events, likening it to an encyclopedia. It stressed that the court should assess matters from the standpoint of a reasonable individual, considering how they would have responded or acted under similar circumstances.

According to the court, the complainant (prosecutrix) had filed an FIR solely against her husband and not against his parents. Neither the written complaint nor the FIR mentioned the husband's parents as individuals who had threatened or colluded in the offense committed by their son.

The prosecutrix had asserted that the petitioners, who were her husband's parents, were complicit in the crime as they were aware of her being raped and blackmailed but chose to remain silent. In her court testimony, she mentioned that her husband's parents had demanded money and jewelry from her. However, it was noted that the prosecutrix had not specifically identified the husband's parents in her statement under Section 161 of the Cr.P.C., where she had mentioned that her husband used to come to collect her jewelry.

The court noted that no incriminating material was found or seized from the husband's parents.

The Court concluded that, in light of the facts presented, it seemed that the petitioners were implicated as accused solely due to their relationship as the father and mother of the primary accused.

The Court further elaborated that simply because the prosecutrix mentioned the husband's parents in her statement under Section 164 of the Cr.P.C. and not in the FIR, it cannot be assumed that the petitioners were involved in the case. Consequently, the court dismissed the criminal proceedings against the husband's parents and granted the petition.

Cause Title: Pradeep Bafna & Anr. v. The State of Madhya Pradesh & Anr.