The Punjab and Haryana High Court on Friday refused to interfere with a dowry harassment case from Faridabad, making it clear that minor errors in a police complaint cannot become a shortcut to quashing an FIR at the threshold. The matter came up before Justice Alok Jain, who heard arguments from both sides and delivered a short but firm oral order.
Background
The petition was filed by Mohd. Arif and other family members, seeking quashing of FIR No. 212 dated June 16, 2025, registered at Dabua Police Station, Faridabad. The FIR invoked Sections 323 (voluntarily causing hurt), 498-A (cruelty by husband or relatives), 506 (criminal intimidation), 509 (insulting modesty of a woman), and 34 (common intention) of the Indian Penal Code.
Counsel for the petitioners argued that the complaint was fundamentally flawed. According to them, the FIR mentioned that the complainant had approached her “saas” (mother-in-law) regarding her husband’s conduct, only to be told she had failed to meet dowry demands. The defence stressed that the mother-in-law had passed away nearly 23 years ago, making the allegation impossible. It was also argued that two of the petitioners were residents of Delhi and never lived in the shared household.
Court’s Observations
Justice Alok Jain examined the FIR carefully and was not persuaded by the argument built around the reference to the mother-in-law. The bench observed that the word “saas” appeared only once in the entire complaint and that, right at the beginning, the complainant had not even named the mother-in-law as an accused.
“The FIR has to be read in totality,” the bench observed, noting that there was no detailed allegation at all against the mother-in-law. The court said the stray reference appeared to be either a typographical mistake or an oversight, not something that could demolish the entire case at this early stage.
On the issue of relatives living separately, the court pointed out that such claims raised disputed questions of fact. These, it said, can only be tested after evidence is led and cannot be conclusively decided while exercising limited powers to quash an FIR.
The judge also took note of the submission that the police challan had already been presented, though it was not placed on record before the court.
Decision
After hearing the petitioners’ counsel at length, the High Court found no ground to exercise its inherent powers. Holding that the allegations required proper examination during trial, Justice Jain dismissed the petition and allowed the criminal proceedings to continue as per law.
Case Title: Mohd. Arif and Others vs State of Haryana and Another
Case No.: CRM-M-68436-2025
Case Type: Criminal Petition (Quashing of FIR)
Decision Date: 05 December 2025
