In a significant ruling on matrimonial disputes, the Bombay High Court has quashed a cruelty case filed under Section 498A of the Indian Penal Code against a husband and his family members. The Nagpur Bench held that general and sweeping allegations, without specific instances of grave cruelty, cannot justify a criminal trial.
Justice Pravin S. Patil delivered the judgment on February 20, 2026, observing that the criminal justice system cannot be used as a pressure tactic in marital conflicts.
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Background of the Case
The case arose from FIR No. 580/2024 registered at Pulgaon Police Station in Wardha district. The complaint was filed by the wife against her husband, parents-in-law, sister-in-law and brother-in-law, alleging mental, physical and financial harassment.
The marriage was solemnised in June 2020. Both spouses are well-educated professionals employed in Pune. Due to the COVID-19 pandemic, the couple initially stayed in Washim before shifting to Pune in 2021.
According to court records , disputes between the couple began during their stay in Pune. The husband had earlier lodged a non-cognizable complaint at Hinjewadi Police Station in February 2024, alleging assault by his wife. Medical examination reportedly showed injuries on him.
Soon after, the husband filed a divorce petition in April 2024. During this period, family meetings were held to explore a mutual settlement. A written agreement dated May 15, 2024 recorded terms for mutual divorce and a one-time financial settlement.
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The wife later terminated her pregnancy at a Wardha hospital. The medical documents showed consent from both parties.
In July 2024, the wife lodged the present FIR alleging cruelty, demand for money and ornaments, pressure to terminate pregnancy, and installation of a hidden camera in her room.
Arguments Before the Court
Counsel for the husband argued that the FIR was filed only after divorce proceedings began and settlement talks failed. It was contended that the allegations were vague and lacked specific dates, acts or details that would constitute cruelty under law.
The wife’s counsel maintained that investigation should not be stalled at the threshold and relied on Supreme Court precedents cautioning against premature quashing of FIRs.
Court’s Observations
Justice Patil examined not only the FIR but also the surrounding circumstances, including WhatsApp messages, the prior police complaint filed by the husband, medical records and the divorce agreement.
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The Court noted that the allegations in the FIR were “general and omnibus in nature” and did not disclose specific acts of grave cruelty as required under Section 498A IPC.
Referring to Supreme Court judgments on misuse of matrimonial provisions, the bench observed:
“The Court is duty-bound to examine the attending circumstances and to pierce the veil of the complaint to ascertain whether the criminal process is being deployed as an instrument of coercion or vendetta.”
On the allegation of a hidden camera, the Court found that the couple had been residing in Pune for most of the relevant period, weakening the claim.
Regarding the termination of pregnancy, the Court relied on the written agreement and medical documents showing consent of both parties. It found no material to support the claim that the procedure was forced.
The judge further remarked that courts must strike a balance between protecting genuine victims and preventing harassment of innocent family members.
“The criminal justice system cannot be reduced to a forum for settling matrimonial scores on the basis of vague and embellished accusations,” the bench said.
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Legal Principles Applied
The Court applied the four-step test laid down by the Supreme Court for quashing proceedings under Section 482 of the Criminal Procedure Code. It held that:
- The applicants had produced credible and unimpeachable material.
- The material was sufficient to rebut the allegations in the FIR.
- The prosecution failed to counter the documented sequence of events.
- Continuing the trial would amount to abuse of the process of court.
The Court emphasised that Section 498A was enacted to curb genuine cruelty but warned against its indiscriminate use against entire families without specific allegations.
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The Decision
Allowing the criminal application, the Court quashed FIR No. 580/2024 registered at Pulgaon Police Station for offences under Section 498A read with Section 34 IPC.
“The continuation of trial would amount to abuse of process of Court,” Justice Patil concluded while making the rule absolute and granting no order as to costs.
Case Title: Vaibhav Gopaldas Mundada & Ors. v. State of Maharashtra & Anr.
Case No.: Criminal Application (APL) No. 1349 of 2024
Decision Date: February 20, 2026
