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by sayum
20 August 2026 1:37 PM
New Delhi, August 31, 2023 — In a landmark judgment, the Supreme Court of India has quashed a dowry harassment FIR against the in-laws of a woman named Bhawna. The bench, comprising Justices ANIRUDDHA BOSE, SANJAY KUMAR, and S.V.N. BHATTI, found the allegations to be "wholly insufficient and far-fetched."
The Court observed, "Given the totality of the facts and circumstances, we are of the considered opinion that Bhawna’s allegations against the appellants, such as they are, are wholly insufficient and, prima facie, do not make out a case against them." The judgment further stated that the allegations were "so farfetched and improbable that no prudent person can conclude that there are sufficient grounds to proceed against them."
The case revolved around allegations of dowry harassment and cruelty against Bhawna's in-laws, Kusum Lata, Abhishek, and Sourabh. The appellants were accused of subjecting Bhawna to mental and physical harassment from 2007 to 2013. However, the Court noted glaring inconsistencies in Bhawna's allegations, particularly concerning her stridhan jewelry and her animosity towards her brother-in-law, Abhishek.
The timing of the complaint also raised eyebrows. Bhawna parted ways with her in-laws in 2009 but did not file a complaint until 2013, just before divorce proceedings were initiated by her husband, Nimish. The Court found this delay significant and stated, "The most significant aspect to be taken note of presently is that Bhawna admittedly parted ways with her matrimonial home and her in-laws in February, 2009, be it voluntarily or otherwise, but she did not choose to make a complaint against them in relation to dowry harassment till the year 2013."
Given these circumstances, the Court exercised its inherent power under Section 482 Cr.P.C. to quash the FIR and the consequential proceedings against the appellants.
Date of Decision: August 31, 2023
Abhishek vs State of Madhya Pradesh
