Facts of the Case

Muskan married Ishaan Khan on 20 November 2020 under Muslim customs, and they had one son. Initially, the relationship was cordial, but within six months, Muskan was allegedly harassed by her husband and in-laws for not bringing sufficient dowry. The husband allegedly demanded ₹50 lakhs from her father to fund his medical education. When the demand was not met, Muskan was abused, slapped, and driven out of her matrimonial home with her child on 27 November 2022.

On 28 January 2024, she filed FIR No. 35/2024 at Alot Police Station, District Ratlam, Madhya Pradesh, naming her husband (Ishaan), mother-in-law, father-in-law, sister-in-law, and brother-in-law as accused under the dowry and cruelty laws.

The accused then approached the High Court under Section 482 CrPC, seeking quashing of the FIR, arguing that the allegations were false, inconsistent, and an “afterthought.” The High Court accepted their plea, holding that the FIR was filed as a “counterblast” to a legal notice from the husband and that earlier complaints did not mention the specific incidents later cited in the FIR.

Arguments

For the Appellant (Muskan):
Her counsel and the State argued that the High Court should not have examined the truth or falsity of allegations at the quashing stage. Even if there were inconsistencies, the FIR contained clear allegations of cruelty and dowry demand — warranting investigation. Reliance was placed on Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra and State of Haryana v. Bhajan Lal.

For the Respondents (Amicus Curiae):
The appointed amicus contended that the FIR was delayed and inconsistent with earlier complaints from 2023. The allegations were vague and lacked specific details against some relatives, warranting quashing under Bhajan Lal principles.

Court’s Observations

The Supreme Court reiterated key principles regarding Section 482 CrPC (inherent powers):

• Quashing should be used sparingly and only when allegations do not prima facie disclose an offence.

• The High Court cannot evaluate evidence or test credibility — doing so amounts to a “mini-trial.”

• The FIR need not be an “encyclopedia”; omissions or minor inconsistencies do not justify quashing.

• Investigation must be allowed to proceed unless the FIR is patently absurd or mala fide.

The Court reviewed Bhajan Lal, Neeharika Infrastructure, Aryan Singh v. CBI, and State of Odisha v. Pratima Mohanty, affirming that unless a complaint is manifestly frivolous or baseless, courts should not interfere at the pre-trial stage.

Judgment and Directions

The Supreme Court held that the High Court erred in quashing the FIR, as the FIR and prior complaints clearly revealed prima facie evidence of cruelty and dowry harassment. The Court emphasized that the absence of specific dates in earlier complaints did not negate the allegations’ substance.

Accordingly, the Supreme Court:

1. Set aside the High Court’s order dated 19 July 2024.

2. Restored the FIR and criminal proceedings against the husband and his relatives.

3. Clarified that all defences are open to the accused during trial, which must proceed on its merits.

Significance

This judgment reaffirms the limited scope of judicial interference under Section 482 CrPC. It protects victims of domestic violence and dowry harassment by ensuring that courts do not prematurely terminate investigations. The Supreme Court underscored that truth and credibility are matters for trial, not for quashing. The ruling strengthens procedural fairness and reasserts that judicial restraint must prevail when prima facie allegations disclose a cognizable offence.