False and Vexatious Cases Cannot Be Allowed to Harass Innocent Families – Supreme Court Quashes 498A Proceedings Initiated After Divorce Case

When Criminal Law is Used as a Weapon of Vengeance, Courts Must Intervene – Supreme Court Strikes Down Dowry Harassment FIR against a husband and his family members, observing that the FIR was filed as an act of vengeance after the husband-initiated divorce proceedings. The Court found the case to be an abuse of the legal system and held that criminal law should not be misused to harass and intimidate innocent individuals.

"It is a matter of grave concern that matrimonial disputes are increasingly being converted into criminal cases to settle personal scores. Courts must be vigilant against such misuse of law," said Justice B.V. Nagarathna, delivering the verdict alongside Justice Satish Chandra Sharma.

The case involved allegations under Sections 498A (cruelty), 504 (intentional insult), and 506 (criminal intimidation) of the IPC, along with Sections 3 and 4 of the Dowry Prohibition Act, 1961. The complainant, Priyanka Mishra, had initially also alleged rape (Section 376 IPC) against her brother-in-law, but after investigation, no charge-sheet was filed for the rape charge. The Supreme Court found that the removal of the rape allegation exposed the entire case as frivolous and retaliatory.

"The timing of the FIR—lodged two months after the husband filed for divorce—raises serious doubts about its genuineness. When allegations arise as a counterblast to divorce proceedings, they must be examined with greater scrutiny," the Court stated.

FIR Filed After Divorce Petition – Supreme Court Finds Allegations Suspicious

The case originated from a matrimonial dispute between Rishal Kumar (Appellant No. 3) and Priyanka Mishra (Respondent No. 2), who were married in 2016. After their relationship soured, Rishal filed for divorce on June 17, 2021. Nearly two months later, on August 19, 2021, Priyanka lodged an FIR, not only against her husband but also against her in-laws, including her mother-in-law, father-in-law, and brother-in-law.

The FIR alleged serious crimes, including rape by the brother-in-law, but after a detailed police investigation, the rape charge was found to be baseless, and no charge-sheet was filed under Section 376 IPC.

The Supreme Court noted that despite not challenging the police’s decision to drop the rape charge, the complainant insisted on pursuing the remaining charges of dowry harassment and cruelty.

"When the most serious charge in the FIR—rape—is found to be false, the credibility of the entire case collapses," the Court observed, adding that "omnibus allegations without specific instances cannot sustain a prosecution."

 “Omnibus Allegations Against Entire Family Are Unacceptable”

The Court found that the FIR did not contain specific details regarding the alleged acts of cruelty or dowry demands. The accusations were vague, general, and lacked any dates or supporting evidence.

Citing its earlier rulings in Iqbal alias Bala v. State of U.P. and Arun Jain v. State of NCT of Delhi, the Court reiterated: “Mere allegations, without concrete evidence, cannot be allowed to drag an entire family into criminal litigation. The criminal justice system cannot be used as a tool for harassment.”

The Supreme Court also took note of the fact that Rishal Kumar had already obtained an ex-parte divorce decree, and that he had remarried. The continuation of criminal proceedings in such circumstances, the Court held, was nothing more than an act of vendetta.

“Once a marriage has legally ended and both parties have moved on, the criminal justice system should not be used to settle past grievances,” the judgment stated.

The Court relied on a series of previous judgments that highlighted the duty of courts to prevent misuse of criminal law in matrimonial disputes.

Referring to Iqbal alias Bala (2023) 8 SCC 734, the Court stated: "When allegations arise in the backdrop of matrimonial discord, courts must look beyond the literal wording of the FIR and examine whether the case is being used as a pressure tactic."

In Mala Kar v. State of Uttarakhand (2024 SCC OnLine SC 1049), where a similar FIR was filed after divorce, the Supreme Court had exercised its powers under Article 142 of the Constitution to quash the criminal case, recognizing that criminal law should not be a means for extracting revenge.

Similarly, in Arun Jain v. State of NCT of Delhi (2024 SCC OnLine SC 1638), the Court had quashed criminal proceedings filed against an entire family, emphasizing that vague and exaggerated allegations should not lead to prolonged criminal trials.

The Supreme Court observed: “The High Court failed in its duty to examine the FIR critically. Instead, it merely stated that since a cognizable offense was alleged, the case must proceed to trial. This is an incorrect approach when allegations appear to be motivated.”

Supreme Court Quashes Criminal Proceedings, Calls for Greater Scrutiny in Matrimonial Disputes

Concluding that the criminal proceedings were nothing more than an attempt to harass the accused, the Supreme Court quashed the FIR and charge-sheet.

"The present case is a textbook example of how criminal law can be weaponized in matrimonial disputes. The entire prosecution appears to be an afterthought, initiated only after the husband sought divorce," the Court stated.

With this ruling, the Supreme Court has reinforced that matrimonial disputes must be resolved through civil remedies and not through frivolous criminal litigation. The decision is expected to serve as an important precedent in preventing false dowry harassment and domestic violence cases, ensuring that only genuine complaints proceed to trial.

This landmark ruling sends a strong message against the misuse of criminal law in matrimonial disputes, emphasizing that courts must guard against the abuse of legal processes and protect innocent individuals from unwarranted prosecution.

Date of decision: 12/02/2025