In a significant relief for three family members accused in a dowry harassment case, the Delhi High Court has quashed the FIR and chargesheet filed against them, observing that the allegations were "vague, contradictory, and an abuse of process of law." Justice Neena Bansal Krishna delivered the judgment on October 8, 2025, in CRL.M.C. 1593/2018, quashing FIR No. 612/2016 registered at P.S. Bindapur, New Delhi.
The case stemmed from a tragic marital breakdown that lasted barely forty days before the husband, Krishna Nand Gupta, took his own life in Pune. His wife, Nisha Gupta, later accused her in-laws-Karuna Sejpal Gupta (sister-in-law), Kanhaiya Ram Gupta (father-in-law), and Kamlesh Gupta (mother-in-law)-of dowry demands and mental cruelty.
Background
Krishna Nand Gupta married Nisha Gupta on March 4, 2016, in Varanasi. The newlyweds went to Malaysia for their honeymoon and settled in Pune, where Krishna worked with a private firm. According to the petitioners, the marriage was simple and no dowry was demanded.
However, tensions soon arose. Within a month, on April 13, 2016, Krishna died by suicide. The in-laws claimed that he was mentally disturbed and under pressure from his wife and her family. Nisha, on the other hand, alleged that her in-laws had constantly demanded ₹14 lakh for constructing a house for the sister-in-law, and that this financial pressure drove her husband to death.
Following the incident, both sides lodged complaints. While the husband’s father filed a report in Pune seeking a fair probe into the suicide, Nisha approached Delhi Police’s Crime Against Women Cell, accusing the in-laws of dowry harassment.
Court's Observations
The bench first examined whether Delhi courts had territorial jurisdiction since the marriage, alleged harassment, and suicide all occurred outside the capital. Justice Krishna, relying on precedents such as Rupali Devi v. State of Haryana and Sunita Kumari Kashyap v. State of Bihar, clarified that "a woman’s mental trauma can continue even after she leaves the matrimonial home," giving Delhi jurisdiction since Nisha was residing here after her husband’s death.
The court then turned to the main issue whether the FIR under Sections 498A, 406, and 34 IPC was based on substantive evidence. Justice Krishna noted that the accusations were largely "bald and omnibus," with no concrete proof of any dowry exchange or harassment.
"The mere booking of tickets or family visits cannot, by any stretch of imagination, be termed as cruelty," the judge remarked, pointing out inconsistencies in Nisha’s statements. At one stage, she claimed the demand was made in Delhi, while at another, in Pune. "Such contradictions erode the credibility of the complaint," the court said.
The bench also analyzed WhatsApp chats between the deceased and his sister, which the complainant herself had produced. Far from showing harassment, the messages revealed "a deeply distressed husband contemplating suicide," with his sister trying helplessly to console him.
"The chats show that the deceased was under his own mental stress," the judge observed, rejecting the notion that the in-laws had instigated him.
Decision
Concluding that no direct evidence linked the in-laws to any dowry demand or cruelty, the Court held that continuing criminal proceedings would amount to injustice. Justice Krishna cited recent Supreme Court rulings Digambar v. State of Maharashtra (2024) and Dara Lakshmi Narayana v. State of Telangana (2024) which cautioned against allowing vague and retaliatory FIRs to stand.
"The present complaint is clearly a case of abuse of process of law," the bench said, adding that "mere bald assertions without corroboration cannot attract Section 498A IPC."
Accordingly, FIR No. 612/2016 registered at P.S. Bindapur, New Delhi, along with all consequential proceedings, was quashed. The petitioners were discharged from the case.
With that, the court closed the matter leaving behind a sobering reminder of how matrimonial disputes, if not handled carefully, can spiral into years of bitter litigation.
Case Title: Smt. Karuna Sejpal Gupta & Ors. vs. State (Govt. of NCT of Delhi) & Anr.
Case Number: CRL.M.C. 1593/2018 & CRL.M.A. 5777/2018
