Did the Supreme Court Quash a Criminal Case Against In-Laws Due to Vague Allegations Under Section 498A IPC?

In a significant ruling, the Supreme Court has quashed a criminal case filed under Section 498A of the Indian Penal Code against the in-laws of a complainant-wife, emphasizing that criminal proceedings cannot be allowed to proceed based on vague and imprecise complaints.

The case involved allegations of cruelty and harassment initiated by the wife against her stepmother-in-law, stepbrother-in-law, father-in-law, and another individual, under Sections 498A, 323, 504, and 506 read with Section 34 IPC. However, the Supreme Court found the allegations to be general and lacking in material specifics, rendering the complaint vague and unclear.

The High Court had previously refused to quash the criminal case, asserting that a prima facie case of cruelty was established under Section 498A. However, the bench, consisting of Justices PS Narasimha and Pankaj Mithal, overturned this decision, stating that the criminal proceedings were initiated with a mala fide intention, primarily aimed at harassing the appellants.

Justice Narasimha, in his judgment, highlighted the lack of truthfulness in the allegations, asserting that it was impossible to substantiate any offense based on such vague assertions. The court emphasized that registering a criminal case based on broad statements would cause injustice to the accused parties.

The court referenced the precedent set in Mohammad Wajid and Another v. State of U.P, which underscored the responsibility of the High Court to scrutinize allegations carefully, especially when they appear manifestly vexatious and malicious.

Notably, the court pointed out that the husband was not named as an accused in this case, observing the unusual nature of the FIR, where the wife chose to initiate criminal proceedings while the husband pursued a civil suit. This suggested a strategic division of their legal actions to advance their interests in the ongoing civil dispute.

The judgment further referred to previous cases, including Jaswant Singh vs. State of Punjab and Usha Chakraborty v. State of W.B, which highlighted the importance of examining the civil context of allegations in criminal cases. The court reiterated that it would be unjust to subject the in-laws to criminal proceedings based on general and vague allegations.

The Supreme Court concluded that no substantial case had been made out in the complaint, thus deeming it appropriate to quash the pending criminal case against the appellants. This ruling serves as a caution against the mechanical registration of domestic violence cases against in-laws and husbands, reaffirming the necessity for clear and specific allegations in criminal proceedings.

Case Title: Kailashben Mahendrabhai Patel & Ors. vs. State of Maharashtra & Anr., Criminal Appeal No. 4003/2024.