NEW DELHI, SEPT. 26, 2025
The Supreme Court of India, in a reportable judgment (2025 INSC 1168), has quashed criminal proceedings against a husband’s father, mother, and sister (the appellants) who were accused under various sections of the Indian Penal Code, including Section 498-A (Cruelty), Section 377 (Unnatural Sex), and Section 506 (Criminal Intimidation), read with Section 34.
The appeal, filed by Sanjay D. Jain & Ors., challenged the High Court’s rejection of their plea to quash FIR No. 20 of 2022.
KEY POINTS
- Case Background: The complainant, who married the son of Appellant Nos. 1 and 2 on July 14, 2021, alleged that demands for gifts/dowry continued after the marriage. The FIR was filed on February 6, 2022.
- The Findings: The Supreme Court determined that the criminal proceedings initiated against the appellants deserved to be quashed.
COURT SAYINGS AND REASONING
Justice Atul S. Chandurkar, authoring the judgment, stated the Court’s rationale for quashing the charges:
On Section 498-A (Cruelty):
- “Vague and general allegations cannot lead to forming of a prima facie case”.
- The Court noted that a review of the FIR indicates “statements of a general nature have been made therein as against the present appellants”.
- Except for one statement regarding a specific call from the mother-in-law demanding clothes and jewelry, “all other statements are of a general nature as well as vague without any particulars”.
- The necessary ingredients for Section 498-A, which requires cruelty to be inflicted with the intention to cause grave injury or drive the victim to commit suicide, are “absent in the present case”.
- The Court found that a prima facie case for proceeding under Section 498-A has “not been made out against the appellants”.
On Sections 377 and 506:
- The Bench observed that the allegations concerning Sections 377 and 506 of the Penal Code (unnatural sex and criminal intimidation) were made “only against the complainant’s husband and not against the present appellants”.
- There is “no allegation whatsoever in that context against the appellants”.
Conclusion on Proceedings:
- The Court held that continuation of these proceedings against the appellants “would amount to an abuse of the process of law”.
CLARIFICATION
The Supreme Court clarified that the decision to quash the FIR against the in-laws does “not come in the way of the respondents in the proceedings initiated against the accused No.1 – husband” under Sections 498-A, 377, and 506 of the Penal Code, which are to be adjudicated on their own merits.
CASE IDENTIFICATION AND PARTIES
| Detail | Description |
|---|---|
| Citation | 2025 INSC 1168 (Reportable) |
| Case Name | SANJAY D. JAIN & ORS. VERSUS STATE OF MAHARASHTRA & ORS. |
| Appeal Number | CRIMINAL APPEAL NO. OF 2025 (Arising out of SLP (CRL.) NO.12584 OF 2024) |
| Date of Judgment | September 26, 2025 |
| Coram | B.R. Gavai, J., K. Vinod Chandran, J., and Atul S. Chandurkar, J. |
| Appellants | Sanjay D. Jain & Ors., consisting of the husband’s father (Appellant No. 1), mother (Appellant No. 2), and sister (Appellant No. 3) |
| Respondents | State of Maharashtra & Ors., where the 2nd respondent is the complainant (wife) |
| Accused No. 1 | Piyush (son of Appellant Nos. 1 and 2, brother of Appellant No. 3), who is the husband of the complainant. He was not an appellant in this proceeding. |
