The Supreme Court on June 4, 2025 quashed a criminal case registered under Section 498A of the Indian Penal Code (IPC) against the husband of a Delhi Police officer and his family. The Court observed that the complaint lacked specific details and noted the increasing misuse of such legal provisions.
A bench of Justices B.V. Nagarathna and Satish Chandra Sharma allowed the criminal appeals in Ghanshyam Soni v. State (Government of Delhi) and others [2025 INSC 803], exercising its powers under Article 142 of the Constitution and quashing FIR No. 1098/2002 and the related chargesheet.
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Background:
The complainant, a police sub-inspector, married Ghanshyam Soni in 1998. She alleged harassment over dowry demand, which included ₹1.5 lakh, a car and a separate house. Physical abuse during pregnancy and threats with a dagger were also mentioned. She first reported the alleged cruelty in 1999 and filed a formal complaint on 03.07.2002, which led to the registration of an FIR on 19.12.2002.
Charges were framed under Sections 498A, 406 and 34 IPC, but the sessions court acquitted the accused in 2008, citing the charges had expired. However, in April 2024, the Delhi High Court overturned it and reinstated the charges, leading to an appeal in the Supreme Court.
Court observations:
The Supreme Court highlighted that the allegations against the mother-in-law and five sisters-in-law were vague and general, with no specific information about the date, time or nature of the cruelty.
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"Even if the allegations and the prosecution case are taken at its face value…no incriminating material is found by either the prosecution or the complainant to prove the elements of 'cruelty' under Section 498A IPC."
The court noted that the complainant failed to produce medical reports, injury records or testimony of supporting witnesses. Even the second complaint filed in 1999 was later withdrawn.
Citing earlier judgments such as K. Subba Rao v. State of Telangana (2018) 14 SCC 452, the Court reiterated:
“Courts should be cautious while proceeding against distant relatives in offences relating to matrimonial disputes…unless there are specific instances of their involvement in the offence.”
The Court acknowledged the High Court’s concern that being a police officer does not make a woman immune from cruelty. However, it emphasised that judicial scrutiny must be based on facts and available evidence and not on assumptions.
On limitation period:
Addressing the issue of delay in filing complaints, the Supreme Court clarified that the limitation period under Section 468 CrPC should be calculated from the date of filing of the complaint and not from the date of taking cognizance by the Magistrate.
“The Magistrate is well within his powers to take cognizance of a complaint filed within a period of three years from the date of the offence.”
The Court relied on Constitution Bench judgments in Sarah Mathew v. Institute of Cardio Vascular Diseases [2014] 2 SCC 62 and Bharat Damodar Kale v. State of Andhra Pradesh [2003] 8 SCC 559 in support of its interpretation.
Final Judgment:
Using its extraordinary powers under Article 142, the Supreme Court quashed the FIR and chargesheet:
“It is unfortunate that the complainant being an officer of the State has unleashed a criminal conspiracy in this manner by pitting aged parents-in-law, five sisters and a tailor as accused.”
The Court emphasised the need to strike a balance between the protection of genuine victims and preventing harassment of innocent persons through baseless prosecution.
Case Title: Ghanshyam Soni v. State (Govt. of NCT of Delhi) & Anr.
