The Supreme Court recently quashed an FIR and chargesheet filed against a husband and his family under Section 498A of the Indian Penal Code (cruelty towards wife), emphasizing that vague and generalized allegations do not warrant the continuation of criminal proceedings.
A Bench of Justice B.V. Nagarathna and Justice Satish Chandra Sharma, in the case of Ghanshyam Soni v. State (Govt. of NCT of Delhi) & Anr. [2025 INSC 803], delivered the judgment, cautioning against the misuse of legal provisions and simultaneously underscoring the importance of safeguarding genuine victims of cruelty.
Background
The complainant, a sub-inspector with the Delhi Police, married Ghanshyam Soni in 1998. She alleged that soon after the marriage, her husband, along with his mother and five sisters-in-law, demanded ₹1.5 lakh, a car, and a separate residence as dowry, and subjected her to both mental and physical abuse. The allegations included being assaulted during pregnancy and threatened with a dagger. She initially filed a complaint on 03.07.2002, which led to the registration of FIR No. 1098/2002 on 19.12.2002 at PS Malviya Nagar, Delhi, under Sections 498A, 406, and 34 of the IPC.
The Magistrate took cognizance of the case on 27.07.2004. Subsequently, the Sessions Court discharged all the accused on 04.10.2008, holding the allegations to be time-barred as they pertained to incidents from 1999. However, in April 2024, the High Court reversed this decision and reinstated the charges, prompting the accused to approach the Supreme Court.
Court’s Findings
The Bench noted that the allegations against the mother-in-law and five sisters-in-law were vague and devoid of specific details about individual conduct or incidents. Citing K. Subba Rao v. State of Telangana (2018) 14 SCC 452, the Court stressed that distant relatives cannot be prosecuted merely on the strength of broad and general accusations.
The Court highlighted that, despite the grave allegations of physical abuse and dowry demands, the complainant did not provide any medical records, injury reports, or corroborating witness statements. It further observed that she had earlier withdrawn a similar complaint, thereby raising questions about the credibility of her claims.
“Even if the allegations and the case of the prosecution is taken at its face value, apart from the bald allegations without any specifics of time, date or place, there is no incriminating material found by the prosecution or rather produced by the complainant to substantiate the ingredients of “cruelty” under section 498A IPC,” the Court observed.
While acknowledging that a police officer can also be a victim of cruelty, the Court cautioned against the misuse of criminal law as a tool to harass family members. It underscored the need to avoid indiscriminate prosecution, especially of distant relatives, to prevent the abuse of judicial process.
“It is rather unfortunate that the Complainant being an officer of the State has initiated criminal machinery in such a manner, where the aged parents-in-law, five sisters and one tailor have been arrayed as an accused. Notwithstanding the possibility of truth behind the allegations of cruelty, this growing tendency to misuse legal provisions has time and again been condemned by this Court.”
The Court referred to the recent ruling in Dara Lakshmi Narayana & Others v. State of Telangana & Another, highlighting its observations regarding the misuse of this legal provision.
Court’s Ruling
Exercising its powers under Article 142 of the Constitution, the Supreme Court quashed FIR No. 1098/2002 and the chargesheet dated 27.07.2004, holding that proceeding with the trial would be unjust and oppressive in light of the absence of specific allegations and credible evidence. The Court observed that while the complaint was filed within the statutory limitation period, the claims were excessively vague and lacked substantive backing to justify a criminal trial. The Bench emphasized the importance of maintaining a balance between ensuring justice for genuine victims and safeguarding the accused from baseless and unwarranted prosecutions.
