The Madhya Pradesh High Court at Jabalpur has refused to quash an FIR arising from a matrimonial dispute, holding that the delay in lodging a complaint cannot, by itself, be treated as a reason to terminate criminal proceedings. Justice Pramod Kumar Agrawal observed that the allegations and evidence involved disputed questions of fact which could not be examined in detail at the stage of a petition seeking quashing of proceedings.
Background
The petition was filed by the husband, father-in-law and mother-in-law seeking quashing of Crime No. 297/2026 registered at Bagsewaniya Police Station, Bhopal, concerning Section 85 of the Bharatiya Nyaya Sanhita. The petitioners argued that the FIR was lodged around 14 months after the wife began residing at her parental home. They also relied on documents concerning gold ornaments, marriage expenses and vehicles to dispute the allegations.
The complainant opposed the petition and alleged harassment and demands for money and other articles. The State also submitted that statements recorded during the investigation contained allegations against the petitioners and that a charge-sheet had already been filed.
The High Court considered the principles governing its power to quash criminal proceedings and noted that such jurisdiction is limited. It held that disputed evidence cannot be tested like a trial at this stage.
The Court observed:
“If a wife maintains patience and remains silent with the intention of saving her matrimonial life, it cannot be said that such conduct amounts to any weakness on her part. On the contrary, it reflects her sincerity and earnest endeavour to save her married life. After realizing that the conduct of her in-laws has not improved and reconciliation is no longer possible, the wife decides to lodge an F.I.R./complaint regarding the cruelty meted out to her, it cannot, merely on account of the delay, be said that the said F.I.R. is a counterblast.”
The Court further noted that the allegations made in the FIR and statements recorded during investigation raised factual issues requiring consideration by the trial court after evidence is recorded. It reiterated that a High Court exercising inherent jurisdiction cannot conduct a mini-trial or assess the correctness and reliability of evidence at this preliminary stage.
Justice Pramod Kumar Agrawal concluded that no ground was made out for quashing the FIR or the consequential criminal proceedings. The Court clarified that its observations were limited to deciding the present petition and would not affect the trial court’s independent assessment of the case.
Accordingly, the petition was dismissed.
Case Details:
Case Title: A. R. v. State of Madhya Pradesh & Others
Case Number: MCRC No. 31871 of 2026
Judge: Justice Pramod Kumar Agrawal
Decision Date: 5 October 2026
