Specific Dates, Sums, and Items Stated — Allegations Cannot Be Brushed Aside as Vague — Supreme Court Restores Dowry Demand Prosecution Against Bridegroom’s Family

“We Are Left to Wonder What More Was Required”, Supreme Court of India tore into a Chhattisgarh High Court ruling that had quashed criminal proceedings against the father, mother, and brother of a prospective bridegroom accused of repeated and substantial dowry demands. The Bench of Justice Dipankar Datta and Justice Augustine George Masih found that the FIR “contained specific and definite allegations with particulars of dates and time” and that the High Court had committed “a serious error” in treating them as “vague and omnibus.”

The Marriage Talks That Turned Into a Criminal Case

The dispute traces back to 2016, when marriage negotiations began between the daughter of the first appellant and the fifth respondent. According to the FIR lodged on 29 November 2016, the talks collapsed because the groom’s family persisted in demanding large sums and valuable items.

The complaint alleged that after the prospective couple met on 15 April 2016, the groom’s brother visited Durg on 4 June 2016 “and suddenly started asking for Rs. 10 lakh in marriage and a vehicle.” Later, on 10 July 2016, the day of the tilak ceremony, the bride’s father was told to give “Rs. 2 lakh in cash along with clothes, silverware and other articles,” which he did. Preparations continued, with the wedding venue and guest accommodations booked on 18 June 2016, complete with advance payments.

But on 21 August 2016, in a telephonic conversation, the groom’s mother allegedly renewed the demand for Rs. 10 lakh and a car. When the bride’s family refused, the marriage was called off.

The High Court’s Quashing and the Supreme Court’s Reversal

The High Court had quashed the proceedings under Section 482 CrPC against the groom’s father, mother, and brother, claiming the FIR made no specific allegations against them, though it allowed the case to proceed against the groom himself.

The Supreme Court, however, saw the matter very differently. Reading the FIR “as it is,” the Bench remarked:

“We do find specific and definite allegations… we are left to wonder what more was required of the 1st appellant to allege that could… constitute full and fair disclosure of offences.”

The Court held that whether the allegations were ultimately true was “entirely a matter for trial” and could not be decided at the quashing stage.

Bhajanlal Defence Rejected

Counsel for the respondents invoked the landmark State of Haryana v. Bhajanlal decision, alleging that the complaint was “manifestly attended with mala fide” and that the bride’s family had misrepresented their status. The Bench was unimpressed, stating:

“Whether or not there has been misrepresentation is entirely a question of fact… to be left for decision at the trial… The present case does not fall in that category.”

The Court pointed out that the High Court itself had not quashed the proceedings on the basis of mala fides or ulterior motive, making the reliance on Bhajanlal misplaced.

“Grave Failure of Justice”

Finding that the High Court’s intervention “occasioned a grave failure of justice,” the Supreme Court set aside the quashing order, restored the proceedings, and directed that the trial run its course “in accordance with law,” cautioning that nothing in its observations should influence the trial court’s assessment of evidence.

Date of Decision: 8 August 2025