The Supreme Court has quashed criminal proceedings against the parents of a man accused in a dowry harassment case, holding that the allegations made against them were vague and lacked specific details. The Court found that the High Court had erred by granting relief to the sister-in-law while refusing the same to the parents-in-law, even though the allegations against all three were similar.
The judgment was delivered by a bench of Justice Vikram Nath and Justice Sandeep Mehta.
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Background of the Case
The dispute arose after the complainant married Dr. Rishi Raj on 8 July 2019. According to the complaint, she was allegedly subjected to cruelty soon after the marriage over demands for a luxury car and other valuables.
In March 2022, an FIR was registered at Lalit Narayan University Police Station in Darbhanga, Bihar. The case was filed under Sections 341, 323, 498A and 34 of the Indian Penal Code along with Sections 3 and 4 of the Dowry Prohibition Act.
The complaint accused the husband, his parents and his sister of harassment and physical assault. It was also alleged that the accused tried to strangle the complainant during an incident in March 2022.
Meanwhile, the husband had already filed a divorce petition under Section 13 of the Hindu Marriage Act in March 2021 before the Family Court in Darbhanga.
After investigation, the police filed a report and the Judicial Magistrate took cognizance of the alleged offences in September 2022.
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High Court Proceedings
The husband’s parents and sister approached the Patna High Court seeking quashing of the criminal case under Section 482 of the Code of Criminal Procedure.
The High Court partly allowed the petition in August 2023. It quashed the case against the sister-in-law, observing that the allegations against her were general in nature. However, the court refused to extend the same relief to the father-in-law and mother-in-law, stating that a prima facie case existed against them.
Aggrieved by this decision, the parents-in-law approached the Supreme Court.
Arguments Before the Supreme Court
Counsel for the appellants argued that the High Court applied different standards while assessing the allegations. According to them, the FIR did not attribute any specific role or overt act to the parents-in-law, and the allegations were as general as those against the sister-in-law.
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They further contended that the FIR appeared to be a retaliatory step after the husband filed a divorce petition. The appellants pointed out that the complaint contained improvements and additional allegations made later in a separate complaint before a magistrate.
On the other hand, the complainant’s counsel argued that the allegations against the in-laws were specific enough and that the trial had already progressed significantly. It was submitted that prosecution evidence had begun and the case should be allowed to proceed.
Supreme Court’s Observations
After examining the FIR and the material on record, the Supreme Court observed that the allegations against the sister-in-law and the appellants were substantially identical.
The bench noted that the FIR did not describe any specific acts committed by the parents-in-law. There were no clear details about dates, places, or individual roles attributed to them.
“The FIR does not assign any specific or overt act to either appellant,” the Court observed, adding that merely stating that the appellants “would quarrel” could not amount to a criminal offence under the provisions invoked.
The Court further noted that the criminal complaint was filed nearly a year after the husband initiated divorce proceedings. While delay alone was not decisive, the absence of specific allegations strengthened the argument that the complaint against the in-laws might have been filed as a reaction to the divorce case.
The bench said the reasoning used by the High Court to quash proceedings against the sister-in-law should have equally applied to the parents-in-law.
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Supreme Court Decision
Allowing the appeal, the Supreme Court set aside the Patna High Court’s order to the extent it refused to quash proceedings against the appellants.
The Court ordered that all criminal proceedings arising out of the FIR registered at Lalit Narayan University Police Station in Darbhanga be quashed in relation to the father-in-law and mother-in-law.
However, the Court clarified that the criminal case against the husband would continue in accordance with law, as he had not sought quashing of the proceedings.
Case Title: Dr. Sushil Kumar Purbey & Anr. v. State of Bihar & Ors.
Case No.: Criminal Appeal (Arising out of SLP (Crl.) No. 3075 of 2024)
Decision Date: 9 March 2026
