The Supreme Court has quashed criminal proceedings against a father-in-law and mother-in-law in a matrimonial dispute, holding that general allegations of cruelty, dowry demand and intimidation, without specific supporting material, were insufficient to subject them to a criminal trial. The judgment was delivered by a Bench of Justice Nongmeikapam Kotiswar Singh and Justice N.V. Anjaria.
Background
The appellants were the father-in-law and mother-in-law of the complainant. She married their son on February 1, 2021, and later began residing with the appellants after her husband was transferred to Siliguri. Following matrimonial disputes, she left the matrimonial home and lodged FIR No. 152/2023 at Siliguri Women Police Station under Sections 498A, 406, 506 and 323 of the IPC, along with Sections 3 and 4 of the Dowry Prohibition Act.
The allegations included dowry demands, verbal taunts, lack of support during pregnancy and an alleged incident in which the complainant was made to sign a document concerning her jewellery and other valuable articles. The police subsequently filed a chargesheet, and the matter was pending before the trial court at the stage of framing of charges.
The Calcutta High Court had earlier quashed only the Section 323 IPC charge against the appellants while allowing the remaining proceedings to continue.
The Supreme Court examined the allegations separately in relation to Sections 498A, 406 and 506 IPC and the Dowry Prohibition Act. It found that the investigation did not disclose independent material establishing specific acts of cruelty, dowry demands, criminal intimidation or misappropriation of property against the appellants.
The Court emphasised that criminal proceedings arising from matrimonial disputes require careful scrutiny, particularly where relatives of the husband are implicated.
“Specific allegations of cruelty, harassment and dowry demands have been made against the husband of the complainant, who was neither a party to the proceedings before the High Court, nor here. Hence, we are not dealing with the allegations against the husband.”
The Court further noted that the allegations against the appellants were not supported by sufficient investigative material or independent witnesses and therefore could not justify continuation of the criminal proceedings.
The Supreme Court held that the complaint and investigation, as they stood, did not disclose sufficient material to warrant subjecting the appellants to a criminal trial. It therefore set aside the Calcutta High Court's order insofar as it had refused to quash the remaining charges.
The Court quashed all proceedings arising from FIR No. 152/2023 against the two appellants under Sections 498A, 406 and 506 IPC and Sections 3 and 4 of the Dowry Prohibition Act, while clarifying that its observations did not concern the merits of the allegation
Case Details
Case Title: Prasanta Kumar Dhar & Anr. v. The State of West Bengal & Anr.
Case Number: Criminal Appeal No. of 2026 (@ SLP (Crl.) No. 16908 of 2024)
Judges: Justice Nongmeikapam Kotiswar Singh and Justice N.V. Anjaria
Decision Date: October 5, 2026
