Courts Can't Hold ‘Mini Trial’ While Quashing FIRs: SC Allows Plea Against Dowry Harassment FIR Quashing

The Supreme Court has held that, at the stage of quashing, a court is not required to conduct a mini trial. The observation came while allowing a woman's appeal against a high court order that had quashed criminal proceedings against her husband and in-laws in a dowry harassment case.

A bench of Justices Sanjay Karol and Prashant Kumar Mishra noted that, ordinarily, for quashing an FIR, it must be shown that there exists no prima facie case against the accused persons. It said the high court failed to adhere to this standard.

One of the major factors that influenced the high court’s decision to quash the case was the absence of specific allegations in the earlier complaints filed by the appellant. The allegations of harassment relating to the incidents of July 22, 2021 and November 27, 2022 appeared for the first time in the FIR registered on January 28, 2024.

However, the Supreme Court observed that the complaints dated January 22, 2023 and January 23, 2023 clearly indicated prima facie allegations of harassment and demand for dowry against the private respondents.

Referring to the scope of the court’s powers under Section 482 of the CrPC, the bench reiterated that at the quashing stage, courts are not expected to engage in a mini trial. The jurisdiction is limited to examining whether sufficient material exists to proceed against the accused. “If sufficient material is available, the power under Section 482 should not be exercised,” the bench said.

Court held that the high court erred in law by delving into the credibility of the allegations in the complaints and the FIR. From a conjoint reading of the complaints and the FIR, the Supreme Court said that prima facie allegations of harassment and dowry demand were evident. Despite this, the high court quashed the FIR primarily on the ground that the earlier complaints did not mention the specific instances of harassment, and that these were added later in the FIR as an afterthought and a counterblast to the legal notice sent by the husband.

“This approach adopted by the high court, in our considered opinion, amounts to conducting a mini trial,” the bench said.

Allowing the appeal filed by Muskan, the Supreme Court set aside the Madhya Pradesh High Court’s order dated July 19, 2024.

The FIR in question was lodged on January 28, 2024 at Police Station Alot, District Ratlam, Madhya Pradesh under Section 498A of the Indian Penal Code, 1860 and Sections 3 and 4 of the Dowry Prohibition Act, 1961 against respondent Nos. 1 to 5.

The marriage between the woman and her husband took place on November 20, 2020 in accordance with Muslim customs. A son was born from the marriage.

According to the woman, within 5–6 months of the marriage, the her husband and in-laws began harassing her, taunting her that her father had given nothing in dowry. Her husband allegedly asked her to bring Rs 50 lakh from her father so that he could pass the MIC examination.

Unable to bear the continued cruelty, she returned to her parental home and lodged the FIR, which was later set aside by the high court before being restored by the Supreme Court.

Case Title: Muskan vs Ishaan Khan (Sataniya) and Others

Order Date: November 6, 2025

Bench: Justices Sanjay Karol and Prashant Kumar Mishra