Sweeping Allegations Without Specifics Cannot Sustain Prosecution Under Section 498A IPC: Supreme Court Quashes FIR Against Brother-in-Law in Dowry Case

In a significant judgment reaffirming judicial caution against vague and generalised accusations in matrimonial disputes, the Supreme Court of India on 24 September 2025 quashed an FIR lodged under Sections 498A and 323 IPC and Sections 3 and 4 of the Dowry Prohibition Act, observing that the allegations against the brother-in-law were “vague, omnibus, and devoid of specific instances or actionable details”.

Bench of Justice B.V. Nagarathna and Justice R. Mahadevan allowed a criminal appeal challenging the Allahabad High Court’s refusal to quash FIR No. 347 of 2023. The FIR was registered by the complainant-wife against her husband, mother-in-law, and the appellant (brother-in-law), alleging dowry harassment and physical cruelty.

The Court held that criminal law cannot be set in motion against family members merely on the basis of vague accusations, and that specific, cogent allegations detailing acts of cruelty are mandatory under Sections 498A and 323 IPC for prosecution to be allowed to proceed.

“Courts Must Scrutinise Matrimonial Allegations With Care to Prevent Misuse of Criminal Law”: FIR Quashed as Allegations Were “Omnibus and Unsubstantiated”

The core question before the Court was whether the High Court had erred in refusing to quash an FIR against the appellant—a relative of the complainant’s husband—when the allegations contained in the FIR were general in nature, lacked specificity, and did not attribute any particular act of cruelty or hurt to the appellant.

The FIR, filed by the complainant-wife on 09.11.2023 at P.S. Civil Lines, Meerut, named her husband, mother-in-law, and brother-in-law (the appellant), alleging harassment and cruelty over dowry demands. The High Court, on 27.02.2024, refused to quash the FIR, noting a prima facie case and observing that the appellant had merely sought protection under Section 41A CrPC rather than a full quashing.

The Supreme Court, however, took a different view, finding that the complaint “lacked time, date, place, and any discernible link between the appellant and the injury allegedly sustained by the complainant”, and hence did not disclose a cognizable offence against him.

“Missing Specifics in FIR Strike at the Root of Criminal Prosecution”: Supreme Court Applies Bhajan Lal Principles to Protect Innocent Relatives

While analysing the FIR, the Court observed that the complainant had made broad, sweeping allegations against the husband’s family without detailing any specific instance of harassment or cruelty that could attract criminal liability under Sections 498A or 323 IPC. The Court held:

“Merely stating that the accused/appellant has mentally harassed the complainant/respondent No.2 with respect to a demand for dowry does not fulfill the ingredients of Section 498A of IPC, especially in the absence of any cogent material or evidence.”

Referring to State of Haryana v. Bhajan Lal (1992 Supp (1) SCC 335), the Court reiterated that criminal proceedings should be quashed where: “The allegations made in the FIR are so vague and general that they do not prima facie constitute any offence.”

The Court found that none of the seven illustrative categories identified in Bhajan Lal were more apt than Category (1) and (7) in this case: “Where the allegations even if accepted in their entirety do not prima facie constitute an offence, and where the criminal proceeding is manifestly attended with mala fide or instituted with an ulterior motive.

“Judicial Experience Shows Tendency to Rope in All Family Members in Matrimonial Disputes Without Basis”: Court Cautions Against Mechanical Prosecution

The Bench referred extensively to its recent decision in Dara Lakshmi Narayana v. State of Bihar, (2025) 3 SCC 735, where it had highlighted the alarming trend of implicating every family member of the husband without credible evidence. The Court quoted:

“A mere reference to the names of family members in a criminal case arising out of a matrimonial dispute, without specific allegations indicating their active involvement should be nipped in the bud.”

In the present case, the Court found that the appellant was dragged into the proceedings simply because of his familial connection, despite no act being attributed to him that would meet the legal definitions of ‘hurt’ or ‘cruelty’ under the IPC.

The Court stressed: “The term ‘cruelty’ under Section 498A IPC cannot be established without specific instances. The FIR must clearly point to offending acts and their perpetrators, not merely level general accusations.”

“We Do Not Say Women Should Remain Silent; But Misuse of Section 498A Cannot Be Tolerated”: Balanced Approach to Protect Law’s Sanctity

Addressing the sensitive nature of matrimonial disputes, the Court clarified that its decision should not be read as discouraging genuine complaints by women. However, it warned against overuse or strategic misuse of criminal law provisions:

“We are not, for a moment, stating that any woman who has suffered cruelty in terms of Section 498A IPC should remain silent… but vague and generalised allegations unsupported by concrete evidence cannot form the basis for criminal prosecution.”

The Court also lamented the strain that indiscriminate FIRs impose on the criminal justice system, noting that prosecutions based on non-specific allegations contribute to judicial backlog and potential miscarriages of justice.

FIR and Proceedings Quashed Against Appellant; Other Matrimonial Cases Unaffected

Finding that the FIR lacked the specificity necessary to initiate or sustain prosecution, the Supreme Court concluded:

“We find that the allegations of cruelty, mental harassment, and voluntarily causing hurt against the accused/appellant herein are vague and general in nature. It is neither expedient nor in the interest of justice to permit the present prosecution to continue.”

Accordingly, the Court allowed the appeal, set aside the Allahabad High Court’s order dated 27.02.2024, and quashed FIR No. 347/2023 dated 09.11.2023 and all consequential proceedings against the appellant only. However, it clarified that the judgment would not affect other matrimonial proceedings pending between the parties.

Date of Decision: 24 September 2025