MUPPIDI LAKSHMI NARAYANA REDDY & ORS.versusTHE STATE OF ANDHRA PRADESH & ANR.
- Citation
- 2025 INSC 562
- Decided
- 23 April 2025
- Disposal
- Case Allowed
- Bench
- AHSANUDDIN AMANULLAH
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 The complainant had earlier withdrawn a restitution of conjugal rights case and later filed a police complaint after the husband sought dissolution of marriage.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
- Code of Criminal Procedure, 1973s. 482
- Dowry Prohibition Act, 1961s. 4
- Indian Penal Code, 1860s. 406, s. 498A
- Information Technology Act, 2002s. 66C
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
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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