The Rajasthan High Court has quashed a long-pending criminal case against the parents-in-law of a woman after noting that the matrimonial dispute between the woman and her husband had already been settled and a divorce decree had been granted following payment of ₹20 lakh as permanent alimony.
Justice Anoop Kumar Dhand held that allowing the criminal proceedings to continue under the circumstances would amount to an abuse of the process of law and would serve no useful purpose.
Background of the Case
The petition was filed by Satyapal Sharma and his wife Sita Devi, who were named as accused in an FIR registered in 2013 at Niwai Police Station in Tonk district.
The complaint had arisen out of matrimonial disputes between their son and his wife, who married in November 2009. Following investigation, a charge sheet was filed against the husband and his parents. Charges were framed in 2018 for offences under Section 498A IPC, Section 406 IPC, and Section 4 of the Dowry Prohibition Act.
Before the High Court, the petitioners argued that the marriage had already ended through a decree of divorce. They further pointed out that the dispute was subsequently settled before a Division Bench of the High Court, where the wife agreed to accept ₹20 lakh as permanent alimony.
According to the petitioners, despite receiving the settlement amount, the complainant had not appeared before the trial court for recording evidence for several years, resulting in the case remaining pending.
The court noted that the husband had obtained a divorce decree from the Family Court in 2019. The wife challenged that decree before the High Court.
During the appeal proceedings, both sides reached a settlement. The Division Bench directed payment of ₹20 lakh as permanent alimony to the wife and her daughter. After the amount was paid, the appeal was dismissed and the divorce decree was finalized.
The High Court observed that the settlement was accepted by both parties and that the husband had fulfilled his obligations under the agreement.
Examining the trial court record, Justice Dhand noted that neither the complainant nor other prosecution witnesses had appeared for evidence since 2018 despite repeated summons.
The court remarked that after accepting the divorce settlement and receiving permanent alimony, the complainant could not seek to continue criminal proceedings against the husband’s family members.
“The conduct of the respondent-wife clearly indicates that the criminal proceedings filed by them were only intended to harass the accused-petitioners,” the court observed.
The judge further stated that courts cannot permit legal proceedings to become a tool of harassment and emphasized that inherent powers can be exercised to prevent misuse of judicial processes.
Referring to the Supreme Court’s decision in Preeti Gupta v. State of Jharkhand, the court reiterated that matrimonial disputes require careful scrutiny and that prolonged criminal trials often deepen bitterness and hardship for all parties involved.
Holding that the dispute had already been settled, the marriage stood dissolved, and the agreed permanent alimony had been paid, the Rajasthan High Court concluded that continuation of the criminal case against the parents-in-law would amount to an abuse of the process of law.
The court accordingly quashed all proceedings arising from the criminal case pending against the petitioners and allowed the criminal miscellaneous petition.
Case Details
Case Title: Satyapal Sharma & Anr. v. State of Rajasthan & Anr.
Case Number: S.B. Criminal Miscellaneous (Petition) No. 4251/2022
Judge: Justice Anoop Kumar Dhand
Decision Date: 21 May 2026
