Case Background

Respondent No. 3 married Puneet Arora on November 9, 2019. She alleged that before marriage, her in-laws demanded a car and insisted on an extravagant wedding costing around ₹30 lakhs. Soon after marriage, her husband and in-laws allegedly used the gift money to buy a car and demanded ₹5 lakhs more from her father, of which ₹2 lakhs were paid. She further claimed she was subjected to verbal abuse, physical assault, and humiliation by her husband and his family, particularly during pregnancy.

While most allegations were against the husband and his immediate family, she also accused the petitioners—Shashi and her daughter—of interfering in her marital life, spreading misinformation, and insulting her parents. The complainant alleged that Shashi threatened her, saying if she “showed tantrums,” her husband would marry Shashi’s daughter instead. She also accused them of daily phone interference, gossiping about her personal matters, and falsely influencing her husband against her.

Additionally, in her statement under Section 161 CrPC, the complainant claimed her stridhan and jewelry were in the possession of her husband, in-laws, and the petitioners. After investigation, a chargesheet was filed against all accused, including the petitioners, leading them to approach the High Court for quashing the proceedings.

Petitioners’ Arguments

The petitioners argued that:

• The FIR was vague, generic, and mala fide, filed only to harass distant relatives.

• They did not reside with the complainant or her in-laws and had no role in any alleged cruelty or misappropriation.

• The allegations were based on trivial family interactions and lacked the essential ingredients of offences under Sections 498A and 406 IPC.
  They relied on several precedents, including Kahkashan Kausar v. State of Bihar (2022), Geeta Mehrotra v. State of U.P. (2012), and Payal Sharma v. State of Punjab (2024), which warned against the misuse of Section 498A by indiscriminately implicating distant relatives.

Respondents’ Arguments

The State and the complainant opposed the quashing, arguing that:

• Specific allegations had been made against the petitioners in the FIR and the Section 161 statement.

• Since the matter was at the stage of charge consideration, the Court should not interfere under Section 482 CrPC.

Court’s Analysis

Justice Mahajan examined the FIR, the complainant’s statements, and the investigation record. The Court reaffirmed that while Section 498A IPC aims to protect women from cruelty and dowry harassment, it has often been misused by making sweeping allegations against the husband’s extended family.

Relying on State of Haryana v. Bhajan Lal (1992), the Court reiterated that proceedings can be quashed where allegations are absurd, improbable, or mala fide. It emphasized that the term “cruelty” under Section 498A requires willful conduct likely to cause grave injury or harassment for unlawful dowry demands.

In this case, the allegations against the petitioners were limited to interference, taunts, and family quarrels, which did not constitute cruelty under Section 498A. They neither lived with the complainant nor engaged in any act of physical or mental harassment. Similarly, the Section 406 charge was based on a vague and omnibus statement that the complainant’s jewelry was with all accused, without any specific entrustment or recovery details.

Judgment

The High Court held that:

• The allegations against the petitioners were general, exaggerated, and insufficient to constitute an offence under Sections 498A or 406 IPC.

• Continuing the prosecution would be an abuse of process of law.
  Accordingly, the FIR and all consequential proceedings were quashed as against the petitioners.

However, the Court left open the possibility for the Trial Court to revive proceedings if credible evidence later emerged against them.

Significance

This ruling reinforces judicial restraint in prosecuting distant relatives under Section 498A IPC without specific, credible allegations. It upholds the balance between protecting genuine victims of domestic violence and preventing misuse of criminal law for vengeance.