The Supreme Court of India has quashed criminal proceedings against Mange Ram, the father-in-law of a woman who had accused him of dowry harassment, citing the end of the matrimonial relationship and lack of proximate allegations.
The case originated when the complainant married Mange Ram's son in December 2017 under the Special Marriage Act. After disputes arose, she left the matrimonial home in May 2019 and later lodged an FIR at Mahila Police Station, Jabalpur, alleging demands for ₹5 lakh, gold ornaments, a motor vehicle, and an incident where Mange Ram allegedly slapped her at Jabalpur Railway Station. The demand was later alleged to have increased to ₹10 lakh.
The Madhya Pradesh High Court had earlier quashed proceedings against the mother-in-law and sister-in-law but refused relief to the father-in-law and husband, citing specific allegations.
However, the Supreme Court noted that the FIR was lodged nearly two months after the alleged incident and only after the husband filed for divorce. It observed that no such allegations were raised during police counselling sessions attended by both parties. The Court also highlighted that the couple had been legally divorced since August 2021 and had moved on with their lives.
Read also:- High Court of Delhi Upholds Prosecution in Income Tax Evasion Case
"Once the marital relationship has ended in divorce and the parties have moved on, continuing criminal proceedings against family members, especially in the absence of specific and proximate allegations, serves no legitimate purpose," the bench of Justices B.V. Nagarathna and K.V. Viswanathan stated.
Invoking Article 142 of the Constitution, the Court set aside the High Court's order and quashed FIR No. 58/2019 and related proceedings, calling further prosecution an abuse of process.
Case Title:- Mange Ram vs. State of Madhya Pradesh & Another
