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Supreme Court of India

MUPPIDI LAKSHMI NARAYANA REDDY & ORS.versusTHE STATE OF ANDHRA PRADESH & ANR.

Citation
2025 INSC 562
Decided
23 April 2025
Disposal
Case Allowed

Holding

In the absence of specific, particularised allegations, the criminal proceedings against the appellants must be quashed under the inherent powers of the court under Section 482 CrPC.

Summary

The appellants, relatives of the husband in a matrimonial dispute, were charged in an FIR alleging they instigated dowry demands, although they lived in Hyderabad while the complainant resided in Guntur. The complainant had earlier withdrawn a restitution of conjugal rights case and later filed a police complaint after the husband sought dissolution of marriage. The appellants sought quashing of the criminal proceedings under Section 482 of the CrPC, arguing that the allegations were vague, omnibus and lacked specific dates or acts. The High Court refused, holding that a trial was required to examine the allegations. The Supreme Court, relying on precedents that caution against prosecuting husband’s relatives on generalized accusations, found no concrete prima facie case and exercised its inherent power under Section 482 to quash the proceedings. Consequently, the appeal was allowed and the criminal case against the appellants was dismissed.

Issues considered

  • Whether the High Court erred in refusing to quash the criminal proceedings against the appellants on the basis of only omnibus and general allegations.
  • Whether the allegations against the appellants constitute a sufficient prima facie case to sustain prosecution under IPC Sections 498A, 406 and the Dowry Prohibition Act.
  • Whether Section 482 CrPC can be invoked to prevent abuse of the judicial process in matrimonial disputes involving alleged dowry demands.

Legislation cited

Headnote

Issue for Consideration Issue arose as regards the correctness of the order passed by the High Court dismissing the petition of the appellants u/s.482 CrPC seeking quashing of the proceedings against them. Headnotes† Code of Criminal Procedure, 1973 – s.482 proceedings – Matrimonial disputes between the parties – In view of the compromise between them, the husband withdrew the case of restitution of conjugal rights and the de-facto complainant-wife withdrew her complaint before the police – Thereafter, the wife left for USA

Subjects

Dowry demandRestitution of conjugal rightsDissolution of marriageLeaving the company of husbandPractice of involving relatives of husband in dowry mattersOmnibus and general allegationsQuashing of the proceedingsCompromise

Judgment

                [2025] 4 S.C.R. 1715 : 2025 INSC 562

             Muppidi Lakshmi Narayana Reddy & Ors.
                               v.
               The State of Andhra Pradesh & Anr.
                    (Criminal Appeal No. 2137 of 2025)
                                23 April 2025
                    [Ahsanuddin Amanullah and
                    Prashant Kumar Mishra,* JJ.]


                           Issue for Consideration
       Issue arose as regards the correctness of the order passed by the
       High Court dismissing the petition of the appellants u/s.482 CrPC
       seeking quashing of the proceedings against them.

                                 Headnotes†
       Code of Criminal Procedure, 1973 – s.482 – Quashing of
       criminal proceedings – Matrimonial disputes between the
       parties – In view of the compromise between them, the
       husband withdrew the case of restitution of conjugal rights
       and the de-facto complainant-wife withdrew her complaint
       before the police – Thereafter, the wife left for USA without
       intimating the husband and the dispute continued – Husband
       filed petition for dissolution of marriage and as a counterblast
       wife again lodged police complaint against accused including
       appellants-sister-in-law of the complainant, her husband and
       her father-in-law – Petition seeking quashing of proceedings by
       the appellants – Dismissed by the High Court – Correctness:
       Held: There are omnibus and general allegations against the
       appellants that they too used to demand dowry or instigate accused
       in demanding dowry – Appellants reside at Hyderabad whereas
       complainant stayed at her marital house at Guntur at the relevant
       point of time and presently she is staying in USA – There is no
       specific date as to when the appellants visited Guntur and joined
       the accused in demanding dowry – Criminal case against the
       appellants quashed. [Paras 8, 9, 11, 12]

                               Case Law Cited
       Geeta Mehrotra & Anr. v. State of Uttar Pradesh & Anr. [2012] 9
       SCR 641 : (2012) 10 SCC 741; Dara Lakshmi Narayana & Ors. v.

* Author
1716                                                     [2025] 4 S.C.R.

                        Supreme Court Reports


     State of Telangana & Anr. 2024 INSC 953 : [2024] 12 SCR 559 –
     relied on.

                              List of Acts
     Penal Code, 1860; Dowry Prohibition Act, 1961; Information
     Technology Act, 2002.

                           List of Keywords
     Dowry demand; Restitution of conjugal rights; Dissolution of
     marriage; Leaving the company of husband; Practice of involving
     relatives of husband in dowry matters; Omnibus and general
     allegations; Quashing of the proceedings; Compromise.

                          Case Arising From
     CRIMINAL APPELLATE JURISDICTION: Criminal Appeal No.
     2137 of 2025
     From the Judgment and Order dated 14.02.2018 of the High Court
     of Judicature at Hyderabad for the State of Telangana and the
     State of Andhra Pradesh in CRLP No. 15126 of 2016

                       Appearances for Parties
     Advs. for the Appellants:
     Dama Seshadri Naidu, Sr. Adv., Siddharth C., Venkateswara Rao
     Anumolu.
     Advs. for the Respondents:
     Abhijit Basu, Sr. Adv., Guntur Pramod Kumar, Ms. Prerna Singh,
     Dhruv Yadav, Keshav Singh, Byrapaneni Suyodhan, Ms. Tatini
     Basu, Ms. Visheshta.

               Judgment / Order of the Supreme Court

                               Judgment

     Prashant Kumar Mishra, J.

     Leave granted.
2.   In the present appeal the appellants have challenged the order
     passed by the High Court whereby their petition under Section 482
     Cr.P.C for quashing proceedings in C.C. No. 359 of 2016 on the file
[2025] 4 S.C.R.                                                        1717

               Muppidi Lakshmi Narayana Reddy & Ors. v.
                  The State of Andhra Pradesh & Anr.

     of the Special Judicial Magistrate, Ist Class for Prohibition & Excise
     Cases, Guntur was dismissed.
3.   The appellant No.1 (A4) is the sister-in-law of the de-facto complainant,
     appellant No. 2 (A5) is the husband of A4 and appellant No. 3 (A6)
     is the father-in-law of appellant No. 1 (A4).
4.   The marriage between de-facto complainant (respondent no. 2) with
     Challa Poornananda Reddy (A1) was solemnised on 24.05.2014 at
     Guntur. After five months of the marriage, the de-facto complainant
     left the company of her husband and joined her parents to live at
     her parental house at Vidyanagar, Guntur. On persuasion, she joined
     her husband but again went back to her parental house and this act
     continued for some more time compelling the husband to send a
     legal notice followed by a petition for restitution of conjugal rights on
     18.02.2015. During the pendency of this proceeding, she lodged a
     complaint before the concerned police on 13.02.2016. However, on
     intervention of elders a compromise was arrived at on 02.04.2015
     and the husband (A1) withdrew the case of restitution of conjugal
     rights and the de-facto complainant also withdrew her complaint
     before the concerned police.
5.   She later left for USA without intimating the husband or his family
     members and the dispute continued. The husband moved a petition
     for dissolution of marriage on 21.06.2016 and as a counterblast she
     again lodged a police complaint bearing FIR No. 79 of 2016 against
     six accused persons including the present appellants.
6.   It is the case of the appellants that they are nowhere connected
     with the dispute between the husband and the wife or the husband’s
     family members. The appellants are residing at Hyderabad. On the
     complaint of the father of the respondent no. 2 (de–facto complainant)
     an offence under Section 66C of the Information Technology Act was
     registered against the husband (A1) which is pending as CC No. 775
     of 2016 before the learned Special Judicial First-Class Magistrate for
     Prohibition and Excise, Gunturu, Andhra Pradesh. It is further case
     of the appellants that accused no. 4 is a housewife, accused no. 5
     is a Software Engineer in a Private Software Company and accused
     no. 6 is a Central Government employee and all are stationed at
     Hyderabad having no connection or intervention with the dispute
     between the de-facto complainant and her husband.
1718                                                        [2025] 4 S.C.R.

                                Supreme Court Reports


7.    The High Court refused to allow the quashing petition on the ground
      that there are allegations against the appellants for which a trial is
      required and the same cannot be disbelieved at this stage.
8.    Having heard learned counsel for the parties and on perusal of
      record it appears that there are omnibus and general allegations
      against the appellants. As per complaint, although, they reside at
      Hyderabad, they used to visit Guntur and during such visit they used
      to instigate accused no. 1/husband and his parents and would also
      join in demanding dowry. The initial allegation is of demand of Rs.
      5,00,000/- made against accused No. 4/appellant no. 1 with further
      statement that they used to taunt that if accused no. 1 would have
      married somewhere else, he would have got Rs. 10 crores dowry.
      There is no allegation of any physical torture being perpetrated by
      the present appellants. The allegation is only of taunt and statement
      that they are highly placed having political influence and connection
      with Ministers as such they instigated accused no. 1 to accused no.
      3 to pressurise the de-facto complainant to get additional dowry.
9.    There is no denial of the fact that the appellants reside at Hyderabad
      whereas the de-facto complainant stayed at Guntur in her marital
      house. There is no specific date as to when the present appellants
      visited Guntur and joined accused nos. 1 to 3 in demanding dowry
      from de-facto complainant. Considering the growing trend of the
      dowry victim arraigning the relatives of the husband, this Court in
      the matter of Geeta Mehrotra & Anr. vs. State of Uttar Pradesh
      & Anr.1 has deprecated the practice involving the relatives of the
      husband for the offence under Section 498A IPC and Section 4 of
      Dowry Prohibition Act, 1961. The following has been held in para 18:
             “18. Their Lordships of the Supreme Court in Ramesh
             case [(2005) 3 SCC 507 : 2005 SCC (Cri) 735] had been
             pleased to hold that the bald allegations made against
             the sister-in-law by the complainant appeared to suggest
             the anxiety of the informant to rope in as many of the
             husband's relatives as possible. It was held that neither
             the FIR nor the charge-sheet furnished the legal basis for
             the Magistrate to take cognizance of the offences alleged
             against the appellants. The learned Judges were pleased


1    [2012] 9 SCR 641 : (2012) 10 SCC 741
[2025] 4 S.C.R.                                                           1719

                 Muppidi Lakshmi Narayana Reddy & Ors. v.
                    The State of Andhra Pradesh & Anr.

            to hold that looking to the allegations in the FIR and the
            contents of the charge-sheet, none of the alleged offences
            under Sections 498-A, 406 IPC and Section 4 of the Dowry
            Prohibition Act were made against the married sister of the
            complainant's husband who was undisputedly not living with
            the family of the complainant's husband. Their Lordships
            of the Supreme Court were pleased to hold that the High
            Court ought not to have relegated the sister-in-law to the
            ordeal of trial. Accordingly, the proceedings against the
            appellants were quashed and the appeal was allowed.”
10. In a recent judgment in the matter of Dara Lakshmi Narayana &
    Ors. vs. State of Telangana & Anr.,2 this Court has again reiterated
    and deprecated the practice of involving the relatives of the husband
    in dowry related matters. The following has been held in paras 24,
    25, 28, 30, 31 & 32:
            “24. Insofar as appellant Nos.2 to 6 are concerned, we
            find that they have no connection to the matter at hand
            and have been dragged into the web of crime without any
            rhyme or reason. A perusal of the FIR would indicate that
            no substantial and specific allegations have been made
            against appellant Nos.2 to 6 other than stating that they
            used to instigate appellant No.1 for demanding more dowry.
            It is also an admitted fact that they never resided with the
            couple namely appellant No.1 and respondent No.2 and
            their children. Appellant Nos.2 and 3 resided together at
            Guntakal, Andhra Pradesh. Appellant Nos.4 to 6 live in
            Nellore, Bengaluru and Guntur respectively.
            25. A mere reference to the names of family members in a
            criminal case arising out of a matrimonial dispute, without
            specific allegations indicating their active involvement
            should be nipped in the bud. It is a well-recognised fact,
            borne out of judicial experience, that there is often a
            tendency to implicate all the members of the husband’s
            family when domestic disputes arise out of a matrimonial
            discord. Such generalised and sweeping accusations
            unsupported by concrete evidence or particularised


2   2024 INSC 953: [2024] 12 SCR 559
1720                                                       [2025] 4 S.C.R.

                       Supreme Court Reports


        allegations cannot form the basis for criminal prosecution.
        Courts must exercise caution in such cases to prevent
        misuse of legal provisions and the legal process and avoid
        unnecessary harassment of innocent family members.
        In the present case, appellant Nos.2 to 6, who are the
        members of the family of appellant No.1 have been living
        in different cities and have not resided in the matrimonial
        house of appellant No.1 and respondent No.2 herein.
        Hence, they cannot be dragged into criminal prosecution
        and the same would be an abuse of the process of the
        law in the absence of specific allegations made against
        each of them.
        28. The inclusion of Section 498A of the IPC by way of
        an amendment was intended to curb cruelty inflicted on
        a woman by her husband and his family, ensuring swift
        intervention by the State. However, in recent years, as there
        have been a notable rise in matrimonial disputes across
        the country, accompanied by growing discord and tension
        within the institution of marriage, consequently, there has
        been a growing tendency to misuse provisions like Section
        498A of the IPC as a tool for unleashing personal vendetta
        against the husband and his family by a wife. Making
        vague and generalised allegations during matrimonial
        conflicts, if not scrutinized, will lead to the misuse of legal
        processes and an encouragement for use of arm-twisting
        tactics by a wife and/or her family. Sometimes, recourse
        is taken to invoke Section 498A of the IPC against the
        husband and his family in order to seek compliance with
        the unreasonable demands of a wife. Consequently, this
        Court has, time and again, cautioned against prosecuting
        the husband and his family in the absence of a clear prima
        facie case against them.
        30. In the above context, this Court in G.V. Rao vs. L.H.V.
        Prasad (2000) 3 SCC 693 observed as follows:
             “12. There has been an outburst of matrimonial
             disputes in recent times. Marriage is a sacred
             ceremony, the main purpose of which is to
             enable the young couple to settle down in
[2025] 4 S.C.R.                                                          1721

               Muppidi Lakshmi Narayana Reddy & Ors. v.
                  The State of Andhra Pradesh & Anr.

                life and live peacefully. But little matrimonial
                skirmishes suddenly erupt which often assume
                serious proportions resulting in commission of
                heinous crimes in which elders of the family
                are also involved with the result that those
                who could have counselled and brought about
                rapprochement are rendered helpless on their
                being arrayed as accused in the criminal case.
                There are many other reasons which need
                not be mentioned here for not encouraging
                matrimonial litigation so that the parties may
                ponder over their defaults and terminate their
                disputes amicably by mutual agreement instead
                of fighting it out in a court of law where it takes
                years and years to conclude and in that process
                the parties lose their “young” days in chasing
                their “cases” in different courts.”
           31. Further, this Court in Preeti Gupta vs. State of
           Jharkhand (2010) 7 SCC 667 held that the courts have
           to be extremely careful and cautious in dealing with
           these complaints and must take pragmatic realties into
           consideration while dealing with matrimonial cases. The
           allegations of harassment by the husband’s close relatives
           who had been living in different cities and never visited
           or rarely visited the place where the complainant resided
           would have an entirely different complexion. The allegations
           of the complainant are required to be scrutinized with great
           care and circumspection.
           32. We, therefore, are of the opinion that the impugned
           FIR No.82 of 2022 filed by respondent No.2 was initiated
           with ulterior motives to settle personal scores and grudges
           against appellant No.1 and his family members i.e.,
           appellant Nos.2 to 6 herein. Hence, the present case at
           hand falls within category (7) of illustrative parameters
           highlighted in Bhajan Lal. Therefore, the High Court, in the
           present case, erred in not exercising the powers available
           to it under Section 482 CrPC and thereby failed to prevent
           abuse of the Court’s process by continuing the criminal
           prosecution against the appellants.”
1722                                                       [2025] 4 S.C.R.

                             Supreme Court Reports


11. In the present case also, it is an admitted position that the appellants
    are residing at Hyderabad whereas the de-facto complainant stayed
    in her marital house at Guntur at the relevant point of time. She is
    presently staying in USA. There is omnibus allegation against the
    appellants that they too used to demand dowry or instigate accused
    nos. 1 to 3 who are not before us, in demanding dowry.
12. Considering the entire facts of the case, we are of the view, having
    relied on this Court’s previous decisions in Geeta Mehrotra (supra) &
    Dara Lakshmi Narayana (supra), the present criminal case against
    the appellants deserves to be quashed. Accordingly, the appeal is
    allowed and Criminal Case No. 359 of 2016 against the appellants
    is quashed.

     Result of the case: Appeal allowed.




     †
         Headnotes prepared by: Nidhi Jain


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