Punjab & Haryana HC Quashes ‘Frivolous’ Dowry Harassment FIR Against In-Laws, Flags Misuse of Section 498A [Read Order]

Punjab: The Punjab and Haryana High Court at Chandigarh has quashed criminal proceedings against three female relatives of an Australia-based man in a dowry harassment case, holding that the FIR was registered out of “vengeance” after a matrimonial dispute had already been resolved by Australian courts.

Justice Amarjot Bhatti delivered the judgment on August 18, 2025, while hearing a plea seeking quashing of FIR No. 47 dated April 23, 2022, registered under Sections 406 and 498-A IPC at the Women Police Station, Sector-17, Chandigarh.

The case was based on allegations by complainant Ravinder Singh against his daughter Neha Chalana’s husband, Rahul Shukla, and his family members—mother-in-law Asha Rani and sisters-in-law Rachna and Nidhi Shukla. The couple had met through matrimonial website Shaadidotcom and married on April 13, 2018.

According to the FIR, after marriage, Rahul returned to Sydney, Australia on April 26, 2018, while Neha traveled to Doha, Qatar on May 3, 2018, before joining her husband in Australia on May 17, 2018. The complainant alleged that matrimonial disputes soon arose in Australia, with Rahul subjecting Neha to cruelty and demanding an additional dowry of ₹8 lakhs.

Justice Bhatti noted that the entire dispute had unfolded in Australia, not India. Neha had filed a domestic violence complaint against Rahul in Australian courts, leading to a Court Order Notice dated April 5, 2019. Subsequently, the Federal Circuit Court of Australia dissolved the marriage on September 12, 2019, after which Neha remarried on November 9, 2020.

The court found the allegations against the female relatives to be baseless, observing:

“There is nothing on record to show that Nidhi Shukla, Rachna Shukla or Asha Rani—petitioners Nos. 2 to 4—ever visited the matrimonial home of Rahul Shukla and Neha Chalana. Therefore, there is no question of any interference on their part in the matrimonial life of the couple.”

In strong remarks on the misuse of law, the court held:

“In fact, registration of the aforesaid FIR is the result of vengeance, as the daughter of respondent No. 2, Neha Chalana, had a matrimonial dispute with her husband. For this reason, respondent No. 2, Ravinder Singh, filed the present complaint against Rahul Shukla and his family members residing in India.”

The FIR was characterized as being based on “frivolous and bald allegations,” amounting to “gross misuse of the process of law.” Justice Bhatti stressed that “no matrimonial dispute took place between the couple during their stay in India” and that “both husband and wife have already taken divorce and moved ahead.”

However, the court declined to quash proceedings against Rahul Shukla himself. It noted that while he had been granted anticipatory bail by the Additional Sessions Judge on December 23, 2024, he subsequently left for Australia in January 2025 without court permission. Justice Bhatti observed:

“Petitioner No. 1 has misused the concession of anticipatory bail granted in his favour.”

The court recorded that a challan had already been filed against the female relatives on May 17, 2024, and that they were currently on bail.

Appearances:
• Mr. Suvir Sidhu, Advocate for the petitioners
• Mr. Manish Bansal, Public Prosecutor, UT Chandigarh with Mr. Navjit Singh for UT Chandigarh
• Mr. Amjad Khan with Mr. Anureet S. Sidhu, Advocate for the complainant

Case Title: Rahul Shukla and Ors. vs. UT Chandigarh and Anr.

[Read Order]