In a significant ruling on matrimonial disputes, the Supreme Court on March 25, 2026, set aside criminal proceedings against a woman’s sister-in-law and elderly parents-in-law, citing lack of evidence and unexplained delay in filing the complaint.
Background of the Case
The case arose from FIR No. 758/2023 registered in Uttar Pradesh’s Lakhimpur Kheri district. The complainant alleged dowry harassment, physical assault, and misconduct by her husband and his family members soon after her marriage in April 2017.
According to the complaint, demands of ₹8.5 lakh and a car were made, and incidents of cruelty including an alleged forced miscarriage and inappropriate conduct by the father-in-law were narrated.
The Allahabad High Court had earlier refused to quash the FIR, observing that the allegations disclosed cognisable offences.
The appellants sister-in-law and parents-in-law argued that:
- They were living separately from the complainant.
- The allegations were vague and unsupported by evidence.
- The FIR was lodged after an unexplained delay of over six years.
The State, however, maintained that the allegations required trial and should not be quashed at the threshold.
The bench found the delay of nearly seven years critical. It noted that no satisfactory explanation was provided for such a long gap.
“The law assists those who are vigilant about their rights,” the Court observed, stressing that delayed complaints weaken the prosecution’s case.
The Court highlighted that the allegations of dowry demand and cruelty were not supported by any material evidence. Mere statements without corroboration, it said, cannot justify criminal prosecution.
It also noted that the charge of causing miscarriage was dropped during investigation due to lack of medical proof.
Referring to past rulings, the Court cautioned against implicating all family members in matrimonial disputes without specific roles.
“General and sweeping allegations… cannot form the basis for criminal prosecution,” the bench noted.
Regarding accusations against the father-in-law under Section 354 IPC, the Court found no specific or detailed evidence to support claims of inappropriate conduct.
Allowing the appeals, the Supreme Court set aside the Allahabad High Court’s order. It quashed:
- FIR No. 758/2023
- Chargesheet No. 01/2024
- Criminal Case No. 634/2025
-so far as they related to the sister-in-law and parents-in-law.
The Court clarified that its observations would not affect any other matrimonial proceedings between the parties.
Case Details
Case Title: Charul Shukla vs State of U.P. & Others
Case Number: Criminal Appeal arising out of SLP (Crl.) Nos. 555 & 609 of 2024
Judge: Justice B.V. Nagarathna, Justice Ujjal Bhuyan
Decision Date: March 25, 2026
