In recent decision, the Supreme Court of India has quashed criminal proceedings initiated against a wife's in-laws under Section 498A of the Indian Penal Code. The Court's ruling was based on its observation that the allegations were predominantly vague and generalized in nature.

The case involved an FIR lodged by a woman against her mother-in-law and two brothers-in-law, one of whom was a judicial officer. After the High Court had declined to quash the proceedings under Section 482 CrPC, the accused parties turned to the Supreme Court for relief.

The Supreme Court bench, comprising Justices Aniruddha Bose, Sanjay Kumar, and SVN Bhatti, scrutinized the case and found several inconsistencies and improbabilities in the allegations. Notably, it was revealed that the complainant had limited interactions with her brothers-in-law, who resided in different cities, primarily during festival seasons. Furthermore, the complainant had only lived in her matrimonial home for about two years, leaving voluntarily in 2009 to reside with her parents.

A pivotal point highlighted by the Court was that the complaint was filed in 2013, shortly after the husband had filed for divorce. Additionally, the wife had anonymously lodged a complaint against her judicial officer brother-in-law, later admitting to being the author of the complaint.

The Court acknowledged that situations where a husband's family members seek to quash criminal proceedings initiated by the wife during matrimonial disputes were not uncommon. The Court cited precedents that supported the quashing of vague and omnibus complaints against in-laws (Kahkashan Kausar alias Sonam and others vs. State of Bihar and others, 2022 LiveLaw (SC) 141). Reference was also made to Mahmood Ali and others vs. State of U.P. and others, 2023 LiveLaw (SC) 613, which emphasized the importance of considering attendant circumstances when assessing the motives behind filing an FIR or complaint due to personal animosity.

The Court found the act of the complainant filing an anonymous complaint against her brother-in-law to be indicative of personal animosity. It also noted the significant gap between the complainant leaving her matrimonial home in 2009 and the subsequent filing of the complaint in 2013.

The Court expressed surprise over the FIR mentioning crimes occurring between 2007 and 2013, despite no allegations of harassment beyond 2009. The complaint lacked specific instances of harassment by the brothers-in-law, and the Court reasoned that the mother-in-law's alleged taunting for wearing a maxi did not constitute cruelty.

Summing up its findings, the Court asserted that the complainant's allegations were predominantly vague and lacking in specific details regarding how and when her brothers-in-law and mother-in-law, residing in different cities, had subjected her to dowry-related harassment.

Furthermore, the Court found it inconceivable that one brother-in-law would demand dowry from his sister-in-law during his own marriage, describing such a scenario as "incongruous and difficult to comprehend." Consequently, the Court concluded that the allegations were "far-fetched" and "improbable."

In light of these considerations, the Court ruled that the allegations against the appellants were wholly insufficient and failed to establish a prima facie case against them. The Court also noted that allowing the criminal process to continue would result in "clear and patent injustice," leading to the quashing of the criminal case.

Case Title: Abhishek v. State of Madhya Pradesh

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