New Delhi: The Supreme Court has quashed criminal proceedings initiated against a mother who was accused of conniving with her son in inducing a woman into a physical relationship on a false promise of marriage, holding that the allegations against her were bland, unsubstantiated and did not inspire confidence.
A Bench of Justices J.B. Pardiwala and K. Vinod Chandran was hearing an appeal filed against an order of the Gujarat High Court declining to quash proceedings initiated on a complaint filed by a woman who alleged that the appellant's son had promised to marry her, and that the appellant had actively connived with her son in the affair, based on which the son obtained sexual favours from the complainant and also appropriated large amounts through the sale of a car owned by her.
The appellant had approached the High Court under Section 482 of the Code of Criminal Procedure, 1973, seeking quashing of the proceedings registered pursuant to an FIR lodged at Modasa Town Police Station, District Aravalli, and pending before the Special Court, Modasa, in Special (Atrocities) Case No.14 of 2024. Mr. Sidharth Mittal, Advocate-on-Record, had been appointed as Amicus Curiae by the Court's order dated 27.02.2026 to represent the second respondent, alongside Mr. Neeraj Kumar Gupta appearing for the appellant and Ms. Swati Ghildiyal appearing for the State.
Examining the First Information Statement, the Court noted that it indicated a consensual relationship between the complainant and the appellant's son, interjected with allegations of a physical relationship forced upon her on the promise of marriage. The statement itself recorded that on one occasion, after the son alighted from a car near a court to attend a proceeding, the complainant had rejected the proposal for marriage, and that the relationship continued only after the son again promised to reform himself, which he evidently did not.
The Court observed that a reading of the First Information Statement did not disclose any allegation giving rise to criminal culpability, noting that "the entire allegations, according to us, inspires no confidence," and that accusations had been made blandly without substantiation despite a chargesheet running to more than two hundred pages.
The Bench also examined translated chats between the complainant and the appellant's son, produced by the appellant herself, observing that the exchange spoke volumes about the complainant's conduct without elaborating further. It further noted that the statement of the complainant's own father, as recorded in the chargesheet, indicated that the complainant was already married and estranged from her husband, with nothing on record to show that a divorce had been obtained. In such circumstances, the Court held that the allegation of the complainant having been led into the relationship by a promise of marriage could not at all be believed.
Holding that the appellant, as the mother of the person against whom the allegations were levelled, "cannot definitely be roped in," the Court found no reason whatsoever to continue the proceedings against her.
Allowing the appeal, the Court quashed the criminal proceedings in Special (Atrocities) Case No.14 of 2024 as against the appellant, arising from Chargesheet No.34/2024 dated 18.06.2024 pursuant to the FIR registered on 19.04.2024. It directed that if the appellant was in prison, she was to be released forthwith, and if she was on bail, her bail bonds would stand cancelled. Pending applications, if any, were disposed of.
Appearances:
For the Appellant: Mr. Neeraj Kumar Gupta, AoR.
For the Respondent State: Ms. Swati Ghildiyal, AoR.
For the 2nd Respondent (Amicus Curiae): Mr. Sidharth Mittal, AoR.
Case Title: Ilaben vs. The State of Gujarat and Anr., Criminal Appeal No.3893 of 2026 (@ SLP (Crl) No.18609 of 2025)
