Madhya Pradesh High Court Quashes Criminal Case Against In-Laws In Dowry Harassment Case In 10-Day Marriage

The Madhya Pradesh High Court has quashed criminal proceedings against the parents of a husband in a dowry harassment case, holding that vague and omnibus allegations without specific material cannot justify subjecting close relatives to the ordeal of a criminal trial.

Justice Vinay Saraf of the High court at Jabalpur passed the order while partly allowing a petition filed by the father-in-law and mother-in-law of the complainant. The court, however, declined to interfere with the proceedings against the husband.

The petition was filed under Section 528 of the Bharatiya Nagrik Suraksha Sanhita, 2023 read with Section 482 of the Code of Criminal Procedure seeking quashing of FIR registered at Police Station Nowgaon in Chhatarpur district. The FIR invoked offences under Sections 85, 115(2), 296, 351(2) and 3(5) of the Bharatiya Nyaya Sanhita, 2023 (corresponding to 498-A, 323, 294, 506 and 34 of the Indian Penal Code) along with Sections 3 and 4 of the Dowry Prohibition Act.

Appearing for the petitioners, advocate Baboo Ji Chourasia argued that the husband’s parents had been implicated in the case merely on the basis of general allegations without any specific act attributed to them. It was submitted that both the FIR and the charge sheet failed to disclose any concrete material indicating their involvement in the alleged offences. The counsel relied on the Supreme Court judgment in Kahkashan Kausar v. State of Bihar to contend that relatives of the husband cannot be prosecuted solely on the basis of vague and omnibus accusations.

The State was represented by panel lawyer Jitendra Shrivastava, while advocate Ashish Kumar Kurmi appeared for the complainant. They opposed the plea, submitting that the accused persons had actively participated in harassing the complainant for dowry and that the allegations were sufficient to proceed with trial.

According to the complainant, the marriage was solemnised on February 13, 2024. Soon after the marriage, she alleged that her husband and his family members began harassing her mentally and physically while demanding additional dowry. It was claimed that despite several articles being given at the time of marriage, the accused demanded a four-wheeler, air conditioner, gold jewellery and cash of five lakh rupees.

The complainant further alleged that she was abused and beaten on multiple occasions and was eventually forced to leave her matrimonial home on February 22, 2024, after which she started residing with her parents.

After examining the record, the High court found that the allegations against the husband’s parents were general in nature and lacked specific details or supporting evidence. The court noted that even the statements recorded during investigation were largely a repetition of the contents of the FIR and did not attribute any distinct role to the in-laws.

The court observed that matrimonial disputes often lead to the tendency of implicating every member of the husband’s family without clear material supporting such accusations. It remarked that in the absence of specific allegations, continuing the criminal proceedings against the husband’s parents would amount to abuse of the process of law.

“The statements recorded during investigation are just a reproduction of the FIR and in the absence of specific allegations against the petitioners they cannot be put to trial,” the court said.

Justice Saraf also relied on multiple Supreme Court decisions, including Preeti Gupta v. State of Jharkhand and Geeta Mehrotra v. State of Uttar Pradesh, which caution courts against permitting prosecution of the husband’s relatives based solely on general allegations in matrimonial disputes.

The court further referred to the Supreme Court’s observations highlighting the growing tendency to implicate the husband’s family members in dowry cases and emphasising that criminal law should not be used as a tool of harassment.

Considering the absence of specific material against the father-in-law and mother-in-law, the court concluded that compelling them to face trial would be unjust.

Accordingly, the High court quashed the FIR and all consequential criminal proceedings against the father-in-law and the mother-in-law. However, the court clarified that the case would continue against the husband.

Case Title: Lokendra Singh Rathore and Others v. The State of Madhya Pradesh and Others

Date of Order: March 11, 2026

Bench: Justice Vinay Saraf