SC Restores Dowry Case, Says High Court Ignored Clear Evidence Against Groom’s Family

The Supreme Court has reinstated criminal proceedings under the Dowry Prohibition Act, 1961, against the father, mother and brother of a prospective groom. The Court held that the Chhattisgarh High Court committed a “serious error” by quashing the case despite specific, date-based allegations of dowry demands.

A Bench of Justice Dipankar Datta and Justice Augustine George Masih delivered the ruling on August 8, 2025, setting aside the High Court’s order of August 20, 2024. The Supreme Court observed that the High Court’s exercise of inherent powers under Section 482 of the Code of Criminal Procedure (CrPC) in this case had “occasioned a grave failure of justice.”

Background of the Case

The matter arose from an FIR lodged on November 29, 2016, by appellant Krishnakant Kwivedy. He alleged that marriage negotiations between his daughter and the fifth respondent broke down because he could not meet continuous demands for dowry made by the groom’s family.

According to the complaint, the marriage discussions began in 2016. On April 15, 2016, the groom met the prospective bride and expressed willingness to marry her. On June 4, 2016, the groom’s brother allegedly demanded Rs. 10 lakh in cash and a vehicle from the complainant.

On July 10, 2016, the day of the tilak ceremony, the complainant claimed to have given Rs. 2 lakh in cash along with clothes, silverware and other articles to the groom’s father, mother and brother. On August 21, 2016, during a phone call, the groom’s mother allegedly repeated the demand for Rs. 10 lakh and a car. The complainant refused to meet these demands, leading to the wedding being called off.

The police filed a charge sheet in the matter on May 27, 2018.

High Court’s Decision

The Chhattisgarh High Court had examined the FIR and concluded that the allegations against the groom’s father, mother and brother were “vague and omnibus” and did not constitute a prima facie offence under Sections 3 and 4 of the Dowry Prohibition Act. The High Court quashed the proceedings against them but allowed the case to continue against the groom himself.

Supreme Court’s Findings

The Supreme Court disagreed with the High Court’s conclusions. After reviewing the FIR, the Bench noted that it contained specific and definite allegations with particulars of dates and times, which, prima facie, included the ingredients of the alleged offences.

The Court stated: “Having read the FIR as it is, we do find specific and definite allegations with particulars of dates and time being disclosed which, prima facie, contain ingredients of offences… We are left to wonder what more was required… We are at a total loss to comprehend as to how the FIR… could have been quashed… holding that the allegations… are vague and omnibus in nature.”

The Bench held that the High Court had erred in quashing the proceedings in the face of such detailed allegations.

Counsel for the respondents sought to defend the High Court’s order by presenting two main arguments. First, they claimed that the complainant had misrepresented his status during the marriage negotiations. Second, they argued that the criminal proceedings were mala fide and relied on the precedent of State of Haryana v. Bhajanlal.

The Supreme Court rejected both arguments. It held that whether the complainant had misrepresented his status was a pure question of fact, which could only be decided during the trial if raised as a defence. On the second point, the Court clarified that the Bhajanlal category of cases relating to proceedings “manifestly attended with mala fide” requires that the mala fide must be apparent on the face of the FIR. This, the Court said, was not the situation here, and in any case, the High Court had not quashed the FIR on mala fide grounds.

Decision and Directions

Finding “little reason to uphold the impugned order,” the Supreme Court set it aside. The Court restored the criminal proceedings under Sections 3 and 4 of the Dowry Prohibition Act against the groom’s father, mother and brother, directing that the case should proceed to its logical conclusion in accordance with law.

The Bench added that none of its observations should influence the trial court in deciding the matter on merits. It emphasised that the trial court must independently assess the evidence and arguments presented by both sides.

Case Title: Krishnakant Kwivedy & Another v. State of Chhattisgarh & Others

Date of Judgment: August 8, 2025

Bench: Justice Dipankar Datta and Justice Augustine George Masih