In a significant decision that may impact dowry harassment cases across the country, the Supreme Court has reinstated criminal proceedings against a husband and his family, after finding that the Madhya Pradesh High Court prematurely quashed an FIR filed by the wife. The bench, led by Justice Prashant Kumar Mishra, held that courts cannot weigh evidence like a trial court while examining a quashing plea.
Background
The case concerns Muskan, who married Ishaan Khan in November 2020 in Ratlam. The couple has a son. According to Muskan, the early months of marriage were peaceful, but soon her husband and in-laws allegedly began taunting her for not bringing dowry. She said the harassment gradually escalated - from verbal abuse to restrictions on food and mobility.
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The FIR states that on two particular dates, the situation turned worse: July 2021, when her brother-in-law allegedly slapped her while demanding dowry, and November 2022, when Ishaan allegedly asked her to bring ₹50 lakh to support his medical studies. After this, she says she was forced out of the marital home with her child.
Muskan first approached the Women’s Cell in January 2023 with complaints of harassment. A formal FIR was registered a year later in January 2024 under Section 498A IPC (cruelty for dowry) and Sections 3 and 4 of the Dowry Prohibition Act.
However, the Madhya Pradesh High Court quashed the FIR, reasoning that the earlier complaints did not mention the two specific incidents later highlighted in the FIR. This, the High Court said, suggested an afterthought.
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Court’s Observations
The Supreme Court disagreed firmly. The bench observed that the High Court had gone beyond its limited role under Section 482 CrPC (the provision allowing quashing of criminal cases in rare instances).
“The High Court embarked upon an enquiry into credibility of allegations, which is not permissible at the quashing stage,” the bench noted.
The Court emphasized that complaints made by women in dowry and matrimonial situations may not always be perfectly chronological or complete the first time. Emotional pressure, family pressures, and threats frequently delay details.
The bench further stated:
“An FIR is not an encyclopedia. All facts need not appear in the earliest complaint. Investigation must be allowed to proceed unless allegations are inherently absurd.”
The Supreme Court also pointed out that the High Court’s approach resembled conducting a “mini-trial” - something repeatedly discouraged in previous judgments like Bhajan Lal and Neeharika Infrastructure.
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Decision
The Supreme Court set aside the High Court’s order and restored the FIR, directing that the trial court must now examine evidence independently, without being influenced by earlier observations.
The bench concluded by noting that all legal defences remain open for the accused during trial, but the investigation and prosecution must not be stopped at the threshold.
The appeal was allowed and proceedings will now continue before the trial court.
Case Title: Muskan vs. Ishaan Khan (Sataniya) & Others
Court: Supreme Court of India
Bench: Justice Sanjay Karol & Justice Prashant Kumar Mishra
Case Type: Criminal Appeal (arising out of SLP (Crl.) No. 1531 of 2025)
Citation: 2025 INSC 1287
Date of Judgment: 06 November 2025