The Supreme Court has ruled that criminal proceedings under Section 498A of the Indian Penal Code, the Dowry Prohibition Act, and the Domestic Violence Act against relatives of a husband must be dropped when the allegations against them are vague, general, and lack specific details showing that they actively participated in cruelty, dowry demands, or domestic violence.
A bench comprising Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh delivered the decision while allowing two connected criminal appeals filed by Arti Mehta and three other relatives of the husband, challenging orders passed by the High Court of Madhya Pradesh, which had refused to quash the proceedings against them.
The wife had alleged that after her marriage in 2019, her husband and his family members, including his sister, mother, brother, and sister-in-law, harassed her for dowry. She lodged an FIR in January 2023 under Section 498A and the Dowry Prohibition Act, and also filed a complaint under the Domestic Violence Act in April 2023. The High Court declined to quash either set of proceedings, holding that there was sufficient material against all the accused and that female relatives could also be named as respondents under the Domestic Violence Act.
The husband argued that the FIR was lodged in retaliation and was filed immediately after he approached the Family Court seeking restitution of conjugal rights. He pointed out that the wife herself, in her divorce petition, admitted that her matrimonial home was at Sheopur, where the husband was posted, and not at Shivpuri, where the relatives lived. This, he argued, showed that there was no shared household with the relatives, as required under the Domestic Violence Act.
The Court found that when the FIR, the domestic violence complaint, and the wife’s own divorce petition were read together, the overwhelming majority of serious allegations were directed solely against the husband. These included physical assault, verbal abuse, locking her in a room, installing hidden cameras, threatening her with a pistol, and suspected involvement with another woman. None of these acts were attributed to the relatives.
As regards the four relatives, the Court found that the allegations were nothing more than broad and sweeping statements that they would demand dowry and tell her to return to her parents’ house. No specific incident, date, or act was mentioned against any of them individually. The Court also noted a telling detail from the wife’s own divorce petition: she had voluntarily travelled from Sheopur to Shivpuri on the occasion of Raksha Bandhan in the company of the very sister-in-law she accused of persistent harassment. This, the Court observed, was inconsistent with the claim of continuous torment.
The Court drew attention to a pattern frequently seen in matrimonial disputes, where complaints allege cruelty not just against the spouse but against the entire family. While genuine cases of family-wide abuse do exist and the law rightly covers them, the Court emphasised that criminal proceedings cannot be initiated against relatives merely because they are related to the husband, failed to intervene, or advised the wife to adjust. Each accused must face specific allegations that prima facie establish their individual role in the offence.
The Court also clarified two important legal points. First, it held that even after a chargesheet has been filed, the High Court retains its power to quash criminal proceedings if the allegations do not make out a case against the accused. Second, it addressed whether quashing the proceedings at this stage would prevent the wife from proceeding against these relatives in the future. The Court held that it would not. Since no trial had taken place, no evidence had been recorded, and no verdict of conviction or acquittal had been rendered, the constitutional guarantee against double jeopardy under Article 20(2) of the Constitution would not apply. If evidence emerges during the ongoing trial of the husband showing that the relatives were actively involved, the trial court would remain free to summon them under Section 319 of the Code of Criminal Procedure.
The Court accordingly set aside both High Court orders and quashed the FIR, the chargesheet, and the domestic violence proceedings against all four relatives. The trial against the husband was directed to continue unaffected.
Case Title: Arti Mehta & Ors. v. The State of Madhya Pradesh & Anr., 2026 INSC 533
