VidhiSangh

Supreme Court of India · 10/12/2024

DARA LAKSHMI NARAYANA & OTHERS versus STATE OF TELANGANA & ANOTHER

[2024] 12 S.C.R. 559 · 2024 INSC 953

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Summary

The Supreme Court quashed an FIR, chargesheet and pending trial under Section 498A IPC and Sections 3 and 4 of the Dowry Prohibition Act against a husband and five of his relatives. The allegations were vague and omnibus, the relatives lived in other cities and faced no specific accusation, and the FIR, lodged after the husband sent a legal notice seeking divorce, was a retaliatory complaint falling within category (7) of Bhajan Lal.

Issues

  1. Whether the High Court erred in refusing, under Section 482 CrPC, to quash an FIR under Section 498A IPC and Sections 3 and 4 of the Dowry Prohibition Act, 1961 lodged by the wife.
  2. Whether vague and general allegations against the husband's relatives who did not live in the matrimonial home could sustain a prosecution.
  3. Whether the FIR was a counterblast to the husband's notice seeking divorce and so an abuse of process.

Provisions considered

Held

Result

Appeal allowed; High Court order set aside and the Section 482 petition allowed; the FIR, the chargesheet and the pending trial against the husband and his five relatives quashed.

Judgment PDF: Supreme Court of India, [2024] 12 S.C.R. 559.