New Delhi: The Supreme Court of India, on December 19, 2025, allowed the appeal of Belide Swagath Kumar, a software engineer, quashing the proceedings against him arising out of an FIR registered under Section 498A of the Indian Penal Code and Sections 3 and 4 of the Dowry Prohibition Act in Telangana. The Bench, comprising Justice B.V. Nagarathna and Justice R. Mahadevan, set aside the order of the Telangana High Court, which had refused to quash the criminal proceedings against the husband.
The case involved FIR No. 29 of 2022 filed by the wife, Smt. Nalla Rashmi, against her husband and his family members after she returned to India from the USA in 2019 due to matrimonial discord. The couple had married in 2016 and had a son. Notably, the High Court had already quashed the proceedings against the husband’s parents and siblings (Accused Nos. 2 to 6) in April 2025.
The Supreme Court critically examined the allegations, which included claims that the husband forced the wife to quit her job, subjected her to physical and mental harassment with dowry demands, controlled her finances, and taunted her regarding her postpartum weight. The Court found these allegations insufficient to warrant a criminal trial.
In its judgment, the Court observed that the allegations put forth by the complainant–respondent No. 2 “reflect the daily wear and tear of marriage and can, in no way, be categorised as cruelty.” Addressing the specific claims, the Bench noted, “The allegation that the accused-appellant forced the complainant-respondent No. 2 to maintain an Excel sheet of all the expenses, even if taken at face value, cannot come under the definition of cruelty.” Furthermore, the Court stated that the “monetary and financial dominance of the accused-appellant, as alleged by the complainant-respondent No. 2, cannot qualify as an instance of cruelty, especially in the absence of any tangible mental or physical harm caused.”
The Court also criticised the lack of specificity in the FIR, stating: “A bare perusal of the FIR shows that the allegations made by the complainant-respondent No. 2 are vague and omnibus. Other than claiming that the husband and his family, along with the accused-appellant herein, mentally harassed her with a demand for dowry, the complainant-respondent No. 2 has not provided any specific details or described any particular instance of harassment.”
Citing the judgment in Bhajan Lal (1992 Supp (1) SCC 335), the Court concluded that the allegations were made with “mala fide intent with vague and general allegations” and that the matter squarely fell within the categories where the extraordinary power to quash should be exercised. The judgment also reiterated caution against the misuse of Section 498A of the IPC, quoting a previous decision: “Courts must exercise caution in such cases to prevent misuse of legal provisions and the legal process, and avoid unnecessary harassment of innocent family members.”
Consequently, the Court allowed the appeal, set aside the High Court’s order, and quashed FIR No. 29 of 2022 along with the consequent proceedings in Complaint Case No. 1067 of 2022.
Case Details:
Case Title: Belide Swagath Kumar v. State of Telangana & Another
Citation: 2025 INSC 1471
Court: Supreme Court of India
Bench: Justice B.V. Nagarathna and Justice R. Mahadevan
Date of Judgment: December 19, 2025
