The Delhi High Court has quashed the FIR lodged against two distant relatives of a husband his aunt (maasi) and her daughter in a dowry harassment case, observing that the allegations were vague, sweeping, and insufficient to amount to cruelty under Section 498A of the Indian Penal Code (IPC).
Justice Amit Mahajan delivered the judgment on November 3, 2025, in Shashi Arora & Anr. vs. State (W.P.(CRL) 2711/2022), bringing relief to the petitioners who had sought quashing of FIR No. 536/2022 registered at Adarsh Nagar Police Station.
Background
The FIR had been filed on the complaint of a woman who accused her husband, in-laws, and other family members including the petitioners of cruelty, assault, and dowry demands. The complainant alleged that after her 2019 marriage, she was harassed for dowry, denied medical care during pregnancy, and humiliated by her husband’s relatives.
Among the accusations, the woman claimed that her husband’s aunt, Shashi Arora, and her daughter Aishley frequently interfered in her marriage, even threatening that Aishley would marry her husband if she did not “behave properly.” She also alleged that her stridhan and jewellery were kept by all in-laws, including the petitioners.
However, both women were living separately from the complainant’s matrimonial home about ten minutes away and were not part of the daily household.
Court's Observations
Justice Mahajan began by acknowledging that while Section 498A IPC was enacted to protect women from cruelty, courts must exercise caution against its misuse. Citing the Supreme Court’s rulings in Kahkashan Kausar v. State of Bihar and Payal Sharma v. State of Punjab, he noted that distant relatives are often over-implicated in matrimonial disputes.
"The court must look carefully when allegations appear far-fetched or inherently improbable," the judge remarked, quoting precedents that emphasize protecting innocent relatives from harassment through false or exaggerated claims.
He observed that the FIR and the subsequent charge-sheet did not contain any specific acts of cruelty or unlawful demand of property by the petitioners. The so-called interference, he said, “at best amounted to occasional family friction or taunts which cannot be equated to the cruelty contemplated under Section 498A.”
On the allegation of misappropriation of stridhan, the Court found only a "broad and unsubstantiated assertion." Justice Mahajan noted that while such general claims might justify an initial investigation, they could not sustain a prosecution once the charge-sheet revealed no evidence against the accused.
"The allegations, even when taken at their face value, do not cross the statutory threshold," the bench observed.
Decision
After analysing the material on record, the Court concluded that no grave suspicion arose against the petitioners to justify framing charges. The judge emphasized that the power to quash proceedings under Section 482 CrPC should be exercised sparingly but firmly when continuation would amount to an abuse of process.
"The petitioners, who neither lived in the matrimonial home nor had any active role in the alleged harassment, cannot be dragged into trial based on mere conjectures," the Court said.
Accordingly, Justice Mahajan quashed the criminal proceedings against Shashi Arora and Aishley Arora arising out of FIR No. 536/2022. However, he left open the possibility for the Trial Court to take appropriate steps if future evidence emerges.
The petition was thus disposed of with these observations.
Case Title: Shashi Arora & Anr. vs. State Through Commissioner of Police & Ors.
