The Supreme Court has quashed criminal proceedings and domestic violence cases against four relatives of a husband, observing that criminal law cannot be invoked against every member of a family merely because a marriage has broken down. The Court said vague and generalized allegations, without specific details of cruelty or dowry demand, are not enough to continue prosecution.
A Bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh passed the judgment while allowing appeals filed by the husband’s sister, mother, brother, and sister-in-law in a matrimonial dispute arising from Madhya Pradesh.
The dispute arose after Sapna Dhakad lodged an FIR in January 2023 against her husband Divyaraj Dhakad and his relatives, alleging cruelty, harassment for dowry, and mental torture. She claimed that cash, jewellery, and household items had been given at the time of marriage and that additional money was later demanded from her family.
Based on her complaint, Police Station Guna registered FIR No. 41/2023 under Sections 498A and 34 of the IPC along with Sections 3 and 4 of the Dowry Prohibition Act. A charge-sheet was later filed before the trial court.
Apart from the criminal case, the complainant also initiated proceedings under the Protection of Women from Domestic Violence Act in 2023 against the same family members.
The Madhya Pradesh High Court had refused to quash both proceedings in November 2024, holding that there was prima facie material against the accused relatives.
After examining the FIR, the domestic violence complaint, and pleadings filed in matrimonial proceedings, the Supreme Court noted that the core allegations were primarily directed against the husband.
The Bench observed that allegations relating to assault, abusive behaviour, hidden cameras, threats with a pistol, and marital discord were specifically attributed to the husband and not to the appellants.
The Court found that the accusations against the relatives were “omnibus and generalised in nature.” It said the complaints did not clearly mention which accused made what demand, when it was made, or how any particular act amounted to cruelty under law.
Referring to one allegation against the husband’s brother Vikram Dhakad, the Bench said his remarks questioning why the complainant was staying in Shivpuri while her husband lived in Sheopur reflected a domestic disagreement rather than criminal conduct.
On allegations against sister-in-law Arti Mehta, the Court observed:
“Mere failure to intervene in a matrimonial dispute between spouses, without any specific allegation of active participation in cruelty or dowry demand, cannot by itself attract criminal liability.”
The Court also noted that the complainant herself had travelled with Arti Mehta during Raksha Bandhan, which weakened the allegation of continuous harassment.
The Bench stressed that courts must carefully scrutinize allegations in matrimonial disputes because there is often a tendency to implicate multiple family members.
The judgment stated:
“Criminal law cannot be permitted to be set in motion against every relative of the husband merely on the basis of generalised and omnibus allegations lacking a specific factual foundation.”
The Court further clarified that merely being related to the husband or siding with him during a marital dispute cannot automatically amount to a criminal offence unless there are clear allegations showing active participation in cruelty or unlawful dowry demands.
Allowing the appeals, the Supreme Court set aside the Madhya Pradesh High Court’s orders dated November 21, 2024. The Bench quashed the FIR, charge-sheet, and domestic violence proceedings against Arti Mehta, Shrivati Bai Dhakad, Manisha Dhakad, and Vikram Dhakad.
However, the Supreme Court also clarified the trial court can later summon the relatives under Section 319 CrPC if strong evidence emerges during trial.
Case Title: Arti Mehta & Ors. v. State of Madhya Pradesh & Anr.
Case Number: Criminal Appeal arising out of SLP (Crl.) No. 18345 of 2024 with connected appeal arising out of SLP (Crl.) No. 1234 of 2025
Bench: Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh
Decision Date: May 25, 2026
