MUSKANversusISHAAN KHAN (SATANIYA) AND OTHERS

                [2025] 11 S.C.R. 273 : 2025 INSC 1287

                               Muskan
                                 v.
                  Ishaan Khan (Sataniya) and Others
                     (Criminal Appeal No. 4752 of 2025)
                               06 November 2025
           [Sanjay Karol and Prashant Kumar Mishra,* JJ.]


                            Issue for Consideration
       Whether the High Court was right in quashing the criminal
       proceedings against the private respondents primarily on the ground
       that the earlier complaints did not mention the two specific incidents
       dated 22.07.2021 and 27.11.2022, which were later on added in
       the FIR and whether the same would not amount to conducting a
       ‘mini trial’ which is clearly prohibited under the scheme of s.482
       of the Cr.PC.

                                    Headnotes†
       Code of Criminal Procedure, 1973 – s.482 – Marriage between the
       appellant and respondent no.1 was solemnized in accordance
       with Muslim traditions and customs – After 5-6 months of
       the marriage, the private respondents started harassing the
       appellant for dowry – Due to continuous cruelty faced by the
       appellant at the hands of the private respondents, she returned
       to her paternal home and registered an FIR u/s.498A of the
       IPC and ss.3 and 4 of Dowry Prohibition Act, 1961 against
       respondent no.1 (husband), respondent no.2 (mother-in-law),
       respondent no.3 (father-in law), respondent no.4 (sister-in-law)
       and respondent no.5 (brother-in-law) – It was stated that on
       22.07.2021, respondents hurled abuses at her and respondent
       no.5 slapped her and asked her to bring dowry – Thereafter,
       on 27.11.2022, respondent No.1, her husband, asked her
       to bring Rs.50 lakhs from her father – Respondents filed a
       petition u/s.482 CrPC for quashing of the FIR – The High Court
       quashed the criminal proceedings – Correctness:
       Held: On the aspect of the powers of the Courts u/s.482 of the
       Cr.PC, it is settled that at the stage of quashing, the Court is not
       required to conduct a mini trial – Thus, the jurisdiction u/s.482 of the


* Author
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       Cr.PC with respect to quashing is somewhat limited as the Court
       has to only consider whether any sufficient material is available
       to proceed against the accused or not – If sufficient material is
       available, the power u/s.482 should not be exercised – In the
       present case, from the conjoint reading of the complaints and the
       FIR, it can be seen that prime facie allegations of harassment and
       demand of dowry are made out, despite that the High Court quashed
       the FIR against the private respondents primarily on the ground
       that the earlier two complaints that were filed by the appellant did
       not mention the specific instances that happened on 22.07.2021
       and 27.11.2022 and the same were later on mentioned in the FIR
       only as an afterthought and was a counterblast to the legal notice
       sent by respondent no.1/husband to the appellant as she was not
       coming back to her matrimonial home – This approach adopted
       by the High Court, in considered opinion of this Court, amounts
       to conducting a mini trial – Accordingly, the present case warrants
       interference – Thus, the impugned order passed by the High Court
       is set aside. [Paras 22, 27, 28]

                                Case Law Cited
       State of Haryana and Others v. Bhajan Lal and Others [1990] 3
       Supp. SCR 259 : (1992) Supp. 1 SCC 335; Daxaben v. State
       of Gujarat and Others [2022] 13 SCR 295 : (2022) 16 SCC 117;
       State of Odisha v. Pratima Mohanty and Others [2021] 9 SCR 335 :
       (2022) 16 SCC 703; Central Bureau of Investigation v. Aryan Singh
       and Others [2023] 2 SCR 819 : (2023) 18 SCC 399; Neeharika
       Infrastructure Private Limited v. State of Maharashtra and Others
       [2021] 4 SCR 1044 : (2021) 19 SCC 401; State of Telangana v.
       Habib Abdullah Jeelani and Others [2017] 1 SCR 141 : (2017) 2
       SCC 779 – relied on.
       Lalita Kumari v. Government of Uttar Pradesh and Others [2013]
       14 SCR 713 : (2014) 2 SCC 1; Mahmood Ali and Others v. State
       of Uttar Pradesh and Others (2023) 15 SCC 488; Digambar and
       Another v. State of Maharashtra and Another [2024] 12 SCR
       1533 : 2024 SCC OnLine SC 3836; Dara Lakshmi Narayana and
       Others v. State of Telangana and Another [2024] 12 SCR 559 :
       (2025) 3 SCC 735 – referred to.

                                  List of Acts
       Penal Code, 1860; Dowry Prohibition Act, 1961.
[2025] 11 S.C.R.                                                       275

             Muskan v. Ishaan Khan (Sataniya) and Others


                            List of Keywords
      Section 482 of Cr.PC; Quashing of FIR; Mini trial; Jurisdiction
      u/s.482 Cr.PC; Dowry; Dowry harassment; Demand of dowry.

                            Case Arising From
      CRIMINAL APPELLATE JURISDICTION: Criminal Appeal No.
      4752 of 2025
      From the Judgment and Order dated 19.07.2024 of the High Court
      of Madhya Pradesh at Indore in MCRC No. 10695 of 2024

                        Appearances for Parties
      Amicus Curiae:
      Prakhar Srivastava.
      Advs. for the Appellant:
      Pavani Verma, Mayank Kshirsagar.
      Advs. for the Respondents:
      Aditya Vaibhav Singh, Pashupathi Nath Razdan, Ms. Maitreyee
      Jagat Joshi, Gautam Singh, Astik Gupta, Ms. Akanksha Tomar,
      Yaduven.

                Judgment / Order of the Supreme Court

                                Judgment

      Prashant Kumar Mishra, J.

1.    Leave granted.
2.    The present Appeal has been preferred against the impugned order
      dated 19.07.2024 in Misc. Criminal Case No.10695 of 2024 passed
      by the High Court of Madhya Pradesh at Indore wherein the High
      Court has quashed the proceedings emanating from FIR No. 35
      of 2024 dated 28.01.2024 registered at Police Station Alot, District
      Ratlam, Madhya Pradesh under Section 498A of the Indian Penal
      Code, 18601 and Sections 3 and 4 of the Dowry Prohibition Act,
      1961 against private respondent Nos.1 to 5 herein.


1    “IPC”
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3.     At the outset, it will be pertinent to mention that respondent Nos.1 to
       5 herein have not entered appearance in the present case and vide
       order dated 28.03.2025, this Court appointed Mr. Prakhar Srivastava,
       learned counsel, as Amicus Curiae to assist the Court (Pro Bono)
       on behalf of the unrepresented respondents.

       A.   FACTUAL MATRIX
4.     Brief facts of the present matter are that the marriage between the
       appellant and respondent No. 1 was solemnized on 20.11.2020 in
       accordance with Muslim traditions and customs. From the marriage,
       a son was born. During the initial days of the marriage, the appellant
       was treated well by respondent No. 1 and his family members.
5.     However, after 5-6 months of the marriage, the private respondents
       started harassing the appellant by taunting her that her father had
       given nothing in dowry. Her husband and other members of his family
       started hurling filthy abuses at the appellant. Further, respondent
       No.1, told the appellant to fetch Rs.50 lakhs from her father so that
       he can pass the MIC examination. He told her, he will only keep her
       if she tells her father to give Rs.50 lakhs.
6.     Due to continuous cruelty faced by the appellant at the hands of the
       private respondents, she returned to her paternal home and registered
       an FIR being FIR No.35 of 2024 registered at Police Station Alot,
       District Ratlam, Madhya Pradesh under Section 498A of the IPC and
       Sections 3 and 4 of Dowry Prohibition Act, 1961 against Ishaan Khan,
       respondent No.1 (husband), Irfana Bee, respondent No.2 (mother-
       in-law), Ishaaq Khan, respondent No.3 (father-in-law), Aaysha Bee,
       respondent No.4 (sister-in-law) and Shahid Khan, respondent No.5
       (brother-in-law).
7.     It was specifically mentioned in the FIR that after 5-6 months of
       marriage, all the above-named persons started taunting her for not
       giving dowry. It was stated that on 22.07.2021, respondent Nos.1
       to 5 hurled abuses at her and her brother-in-law, who is respondent
       No.5, slapped her and asked her to bring dowry. Thereafter, on
       27.11.2022, respondent No.1, her husband, asked her to bring
       Rs.50 lakhs from her father as he wanted to pursue further medical
       studies. Pursuant to which, her husband ousted both, the appellant
       and their son Iwaan Khan, from the matrimonial house. Thereafter,
[2025] 11 S.C.R.                                                               277

                   Muskan v. Ishaan Khan (Sataniya) and Others


       the appellant started residing with her parents. It was further stated
       on behalf of the appellant that her father made several attempts to
       reconcile differences, but the private respondents were adamant in
       their demand for the sum of Rs.50 lakhs.
8.     Against FIR No.35 of 2024, respondent Nos.1 to 5 preferred
       Miscellaneous Criminal Case No.10695 of 2024, a petition under
       Section 482 of the Code of Criminal Procedure Code, 19732, for
       quashing of the said FIR registered under Section 498A of the IPC
       and Sections 3 and 4 of the Dowry Prohibition Act, 1961 and all
       further proceedings arising therefrom.
9.     The High Court vide the impugned order dated 19.07.2024 allowed
       the Miscellaneous Criminal Case No.10695 of 2024. Being aggrieved
       thereby, the present Appeal has been filed.
10. While issuing notice in this matter, this Court passed the following
    order on 24.01.2025:
               “1. Delay condoned.
               2. We have perused the complaint dated 23rd January,
               2023, filed by the instant petitioner at the concerned police
               station, which is part of the additional documents filed by
               the petitioner (page no.6).
               3. Prima facie, we are of the view that the matter requires
               consideration, more so, in view of the observation made
               by the High Court in Para No.10 of the impugned order.
               4. Issue notice, returnable on 28.02.2025.
               5. Dasti service, in addition, is permitted. Steps for service
               be taken within two weeks.”
                                                      (emphasis supplied)

       This Court noted that this matter requires consideration, more so,
       in view of the observation made by the High Court in paragraph 10
       of the impugned order.




2    For short, ‘the Cr.PC’
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       B.   SUBMISSIONS OF PARTIES
11. We have heard the learned counsel for the appellant, learned Amicus
    Curiae for the unrepresented private respondent Nos.1 to 5 and
    learned counsel for respondent No.6-State of Madhya Pradesh.
12. Learned counsel appearing on behalf of respondent No.6/State
    argues that power of quashing should be exercised only in rarest of
    rare cases. The High Court while examining an FIR/complaint ought
    not to embark upon an enquiry as to the reliability and genuineness
    of allegations. It was also argued that merely because the appellant
    did not mention the two specific incidents earlier in the complaints
    before registration of the FIR, the same could not have been termed
    as an afterthought when other specific allegations of harassment
    and demand of dowry were mentioned. To bolster his submissions,
    reliance has been placed on the decisions of this Court in Neeharika
    Infrastructure Private Limited v. State of Maharashtra and Others3
    and State of Haryana and Others v. Bhajan Lal and Others4.
13. Learned Amicus Curiae appearing on the behalf of the private
    respondents submits that a bare perusal of the complaints dated
    22.01.2023 and 23.01.2023 lodged by the appellant before the
    Women’s Cell in Ratlam and the subsequent FIR dated 28.01.2024
    would reveal that there are some inconsistencies in the contents
    thereof. The complaints filed before the Women’s Cell in Ratlam
    are generic in nature whereby the appellant had inter alia alleged
    that since her marriage, she was not being treated properly and was
    subjected to abuses and constant taunts for not bringing enough
    dowry and respondent No. 2 i.e. the mother-in-law, was not providing
    enough food and water to her whilst also keeping her under constant
    surveillance. Interestingly, there is no mention of either of the two
    dates i.e. 22.07.2021 and 27.11.2022. Further, there is no mention
    of a crystallized amount of dowry allegedly demanded by respondent
    Nos. d1 to 5 in these complaints.
14. It was further argued that the appellant was allegedly ousted
    from her matrimonial home on 27.11.2022 by respondent No.1.
    Thereafter, she filed a complaint before the Women’s Cell, Ratlam



3   (2021) 19 SCC 401
4   1992 Supp (1) SCC 335
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                Muskan v. Ishaan Khan (Sataniya) and Others


     on 22.01.2023 whereas the FIR was lodged after a delay of 1 year
     i.e. on 28.01.2024. Further, the contents of the FIR reveal that the
     appellant has not made specific allegations against respondent
     Nos. 2 to 4 and merely vague and omnibus averments have been
     made, which even if relied on their face value, do not constitute the
     commission of a cognizable offence.
15. To bolster his submissions, learned Amicus Curiae has relied on
    the decisions of this Court in Lalita Kumari v. Government of
    Uttar Pradesh and Others5, Mahmood Ali and Others v. State
    of Uttar Pradesh and Others6, Digambar and Another v. State
    of Maharashtra and Another7 and Dara Lakshmi Narayana and
    others v. State of Telangana and Another8.
16. The rival submissions now fall for our consideration.

     C.     ANALYSIS
17. The main issue that arises for our analysis is whether the High Court
    was right in quashing the criminal proceedings against the private
    respondents primarily on the ground that the earlier complaints
    did not mention the two specific incidents dated 22.07.2021 and
    27.11.2022, which were later on added in the FIR and whether the
    same would not amount to conducting a ‘mini trial’ which is clearly
    prohibited under the scheme of Section 482 of the Cr.PC.
18. At the outset it will be appropriate to advert to the observations made
    by the High Court in paragraphs 9 and 10 of the impugned order:
            “9. It is undisputed that prior to filing FIR (Annexure P/5),
            a written complaint dated 22.01.2023 (Annexure P/3) was
            filed before Mahila Police Station, Ratlam, District Ratlam
            (MP) for the alleged harassment meted out to respondent
            No.2 from her husband and in-laws (applicants before this
            Court). It is also not in dispute that both the parties i.e.
            applicant No. 1 and respondent No.2, on their counter
            allegations, were advised by Police Mahila Thana, Ratlam


5   (2014) 2 SCC 1
6   (2023) 15 SCC 488
7   2024 SCC OnLine SC 3836
8   (2025) 3 SCC 735
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          to take recourse of law, but no action was taken on the
          above 3 MCRC-10695-2024 complaint by respondent No.2.
          In such a situation, if respondent No.2 was aggrieved of
          advice dated 23.01.2023 given by Mahila Police Station,
          Ratlam, she might have approached the Superintendent
          of Police for inaction on the part of the concerned Police
          Station on her complaint, but this has not been done.
          10. It is also pertinent to note that in the (sic) above written
          complaint, there has not been a whisper of the events of
          harassment on 22.07.2021 and 27.11.2022, as narrated
          in the FIR (Annexure P/5). It manifests that the alleged
          incidents of harassment meted out to the complainant
          allegedly took place on 22.07.2021 and 27.11.2022 are
          afterthought. The contentions raised on behalf of the
          applicants that FIR (Annexure P/5) is a counterblast
          to notice (Annexure P/1) given by applicant No. 1 to
          respondent No.2 also finds support from the above.”
                                                   (emphasis supplied)

19. From a bare perusal of the above mentioned paragraphs it can be
    seen that one of the important factors that weighed in while allowing
    the quashing application of the private respondents was that in
    the earlier complaints filed by the appellant, there was no mention
    of the events of harassment that happened on 22.07.2021 and
    27.11.2022, which were later on added in the FIR dated 28.01.2024.
    Hence, we extract the relevant portion of the complaints dated
    22.01.2023 and 23.01.2023 which would clearly indicate prime facie
    allegations of harassment and demand of dowry against the private
    respondents:
                                                            “22.01.2023
          …That immediately after the Nikah, the respondents
          namely Ishan, father-in-law Ishaq Khan, mother-in-law
          Irfana Bi, sister-in law (Nanad) Ayesha, Nandoi Shayid
          Khan, Jeth Hemuddin son of Akbar Khan resident of
          Ujjain started raising demand of dowry from me. They
          are constantly causing physical and mental harassment
          for the last two years. A demand of dowry is being raised
          every day since the day of my marriage. My father gave
[2025] 11 S.C.R.                                                       281

             Muskan v. Ishaan Khan (Sataniya) and Others


          a Pulsar Bike but I was asked to bring a car. On the
          occasion of my sister-in-law’s wedding, they asked me
          to ask my father to give an A.C to their daughter Ayesha
          in the dowry. My mother-in-law did not allow my husband
          to come to the hospital at the time of my delivery. At the
          time of my ‘God-Bharai’, she demanded clothes and my
          mother-in-law puts restrictions on my eating food and
          having breakfast. She asks me to eat the same vegetable
          three times a day and asks me not to eat breakfast, she
          lets me drink tea once a day, she has installed cameras in
          my kitchen. My mother-in-law locks me in the house from
          outside. She does not allow me to talk to my husband. My
          husband would come to me at 11 o’clock in the night and
          would quarrel with me and assault me. My sister-in-law
          and brother-in-law would come to Ghosla almost every
          day and would scare me and threaten to kill me. They do
          not give me my mobile phone, they do not let my family
          members come to Ghosla and talk to me even on the
          phone. It is the daily routine of my father-in-law to hurl
          abuses morning and evening.”
                                     *****
                                                         23.01.2023
          …. Since after my marriage, I have been tortured and
          threatened. Ask your father to give a car and a demand
          was raised for an A.C. in my sister-in-law’s marriage.
          When the demand could not be fulfilled by my father, I
          am being made to eat same vegetable for three days and
          they do not allow me to take my breakfast and I am given
          tea only once in a day.
          My mother-in-law, sister-in-law, brother-in-law and father-
          in-law come together to my room and hurl abuses and
          threaten me. My father-in-law hurls abuses in obscene
          language and my mother-in-law makes me work the entire
          day and does not let me eat anything. My sister-in-law
          and brother-in-law everyday tell my mother-in-law to send
          him away over the phone. Many times they confine me
          in the room and lock the same from outside and I am not
          allowed to go out and I am not even allowed to open the
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            window of the house. They have confined me as hostage
            in the house for many days. They do not let me talk to my
            family on phone and do not even let my family members
            meet me. My husband is also involved in all this. He never
            gives me even 2 rupees for expenses. They do not even
            allow me to visit my relatives. As such, being troubled by
            all this, I came to my parents’ house.
            ….”
       It is also apposite that we extract the relevant portions of the FIR so as
       to better understand the allegations against the private respondents,
       particularly the two specific incidents that happened on 22.07.2021
       and 27.11.2022. The relevant extract reads thus:
            “…..I kept tolerating their taunts in order to save my
            marital life. But on 22.07.2021, my husband Ishan Khan,
            mother-in-law Irfana Bee, father-in-law Ishaq Khan, sister-in
            law Aaysha Bee and brother-in-law (Nandoi) Syed Khan
            hurled abuses to me. My brother-in-law (Nandoi) Syed
            Khan slapped me also and asked me to bring dowry from
            your father’s house. Despite all this, I kept tolerating their
            torture. But on 27.11.2022, my husband Ishan Khan told
            me that I have passed the examination of M.B.B.S. and
            now I have to pursue M.C.I. Examination, as such, now if
            you will bring an amount of Rs. fifty lacs from your father,
            only then, I will keep you with me and say this, he ousted
            me and my son Iwaan Khan from the house while holding
            our hand. Thereafter, I came to my father Zahid Khan’s
            house at Alot and narrated the entire incident to my father
            and mother Parveen Bee. Since then, I am residing at
            Alot alongwith my father. My father made several attempts
            to make my husband and in-laws understand but these
            people are adamant for their demand of dowry of a sum
            of Rs. fifty lacs that unless and until, they are given a
            dowry of Rs. fifty lacs, they will not take me with them.
            Today, I have come to make a report in the police station
            alongwith my father Zahid Khan. I lodge the report, action
            may be taken.”
                                                    (emphasis supplied)
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             Muskan v. Ishaan Khan (Sataniya) and Others


20. The classic exposition on law under Section 482 of the CrP.C is
    found in Bhajan Lal (supra) wherein this Court elaborated upon the
    scope of Section 482 of the Cr.PC. It was held thus:
          “102. In the backdrop of the interpretation of the various
          relevant provisions of the Code under Chapter XIV and of
          the principles of law enunciated by this Court in a series of
          decisions relating to the exercise of the extraordinary power
          under Article 226 or the inherent powers under Section
          482 of the Code which we have extracted and reproduced
          above, we have given the following categories of cases by
          way of illustration wherein such power could be exercised
          either to prevent abuse of the process of any court or
          otherwise to secure the ends of justice, though it may not
          be possible to lay down any precise, clearly defined and
          sufficiently channelized and inflexible guidelines or rigid
          formulae and to give an exhaustive list of myriad kinds of
          cases wherein such power should be exercised.
          (1) Where the allegations made in the first information
          report or the complaint, even if they are taken at their
          face value and accepted in their entirety do not prima
          facie constitute any offence or make out a case against
          the accused.
          (2) Where the allegations in the first information report
          and other materials, if any, accompanying the FIR do not
          disclose a cognizable offence, justifying an investigation
          by police officers under Section 156(1) of the Code except
          under an order of a Magistrate within the purview of Section
          155(2) of the Code.
          (3) Where the uncontroverted allegations made in the FIR
          or complaint and the evidence collected in support of the
          same do not disclose the commission of any offence and
          make out a case against the accused.
          (4) Where, the allegations in the FIR do not constitute a
          cognizable offence but constitute only a non-cognizable
          offence, no investigation is permitted by a police officer
          without an order of a Magistrate as contemplated under
          Section 155(2) of the Code.
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            (5) Where the allegations made in the FIR or complaint
            are so absurd and inherently improbable on the basis of
            which no prudent person can ever reach a just conclusion
            that there is sufficient ground for proceeding against the
            accused.
            (6) Where there is an express legal bar engrafted in any
            of the provisions of the Code or the concerned Act (under
            which a criminal proceeding is instituted) to the institution
            and continuance of the proceedings and/or where there
            is a specific provision in the Code or the concerned Act,
            providing efficacious redress for the grievance of the
            aggrieved party.
            (7) Where a criminal proceeding is manifestly attended
            with mala fide and/or where the proceeding is maliciously
            instituted with an ulterior motive for wreaking vengeance
            on the accused and with a view to spite him due to private
            and personal grudge.”
21. In Daxaben v. State of Gujarat and Others9, a two-Judge Bench
    held as follows:
            “26. Even though, the inherent power of the High Court
            under Section 482 CrPC, to interfere with criminal
            proceedings is wide, such power has to be exercised with
            circumspection, in exceptional cases. Jurisdiction under
            Section 482 CrPC is not to be exercised for the asking.
            27. In Monica Kumar v. State of U.P. [(2008) 8 SCC 781 :
            (2008) 3 SCC (Cri) 649], this Court held that inherent
            jurisdiction under Section 482 CrPC has to be exercised
            sparingly, carefully and with caution and only when such
            exercise is justified by the tests specifically laid down in
            the section itself.
            28. In exceptional cases, to prevent abuse of the process
            of the Court, the High Court might in exercise of its inherent
            powers under Section 482 quash criminal proceedings.
            However, interference would only be justified when the



9   (2022) 16 SCC 117
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                 Muskan v. Ishaan Khan (Sataniya) and Others


             complaint did not disclose any offence, or was patently
             frivolous, vexatious or oppressive, as held by this Court
             in Dhanalakshmi v. R. Prasanna Kumar [1990 Supp SCC
             686 : 1991 SCC (Cri) 142 : AIR 1990 SC 494] .
                                        *****
             36. Offence under Section 306 IPC of abetment to commit
             suicide is a grave, non-compoundable offence. Of course,
             the inherent power of the High Court under Section 482
             CrPC is wide and can even be exercised to quash criminal
             proceedings relating to non-compoundable offences, to
             secure the ends of justice or to prevent abuse of the
             process of court. Where the victim and offender have
             compromised disputes essentially civil and personal in
             nature, the High Court can exercise its power under Section
             482 CrPC to quash the criminal proceedings. In what cases
             power to quash an FIR or a criminal complaint or criminal
             proceedings upon compromise can be exercised, would
             depend on the facts and circumstances of the case.”
22. On the aspect of the powers of the Courts under Section 482 of the
    Cr.PC, it is settled that at the stage of quashing, the Court is not
    required to conduct a mini trial. Thus, the jurisdiction under Section
    482 of the Cr.PC with respect to quashing is somewhat limited as
    the Court has to only consider whether any sufficient material is
    available to proceed against the accused or not. If sufficient material
    is available, the power under Section 482 should not be exercised.
23. This Court in the case of State of Odisha v. Pratima Mohanty and
    Others10 held that:
             “8.2. It is trite that the power of quashing should be
             exercised sparingly and with circumspection and in rare
             cases. As per the settled proposition of law while examining
             an FIR/complaint quashing of which is sought, the court
             cannot embark upon any enquiry as to the reliability or
             genuineness of allegations made in the FIR/complaint.
             Quashing of a complaint/FIR should be an exception rather
             than any ordinary rule. Normally the criminal proceedings


10   (2022) 16 SCC 703
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             should not be quashed in exercise of powers under
             Section 482 CrPC when after a thorough investigation
             the charge-sheet has been filed. At the stage of discharge
             and/or considering the application under Section 482CrPC
             the courts are not required to go into the merits of the
             allegations and/or evidence in detail as if conducting the
             mini-trial. As held by this Court the powers under Section
             482 CrPC are very wide, but conferment of wide power
             requires the court to be more cautious. It casts an onerous
             and more diligent duty on the Court.”
24. Further in the case of Central Bureau of Investigation v. Aryan
    Singh and Others11, this Court held that at the stage of Section 482
    of the Cr.PC, the High Court is not required to conduct a mini trial.
             “6. From the impugned common judgment and order [Aryan
             Singh v. CBI, 2022 SCC OnLine P&H 4158] passed by the
             High Court, it appears that the High Court has dealt with the
             proceedings before it, as if, the High Court was conducting
             a mini trial and/or the High Court was considering the
             applications against the judgment and order passed by
             the learned trial court on conclusion of trial. As per the
             cardinal principle of law, at the stage of discharge and/or
             quashing of the criminal proceedings, while exercising the
             powers under Section 482 CrPC, the Court is not required
             to conduct the mini trial. The High Court in the common
             impugned judgment and order has observed that the
             charges against the accused are not proved. This is not
             the stage where the prosecution/investigating agency is/are
             required to prove the charges. The charges are required
             to be proved during the trial on the basis of the evidence
             led by the prosecution/investigating agency.”
                                                    (emphasis supplied)

25. This Court in Neeharika Infrastructure Private Limited (supra)
    gave following directions to the Courts exercising the power under
    Section 482 of the Cr.PC:



11   (2023) 18 SCC 399
[2025] 11 S.C.R.                                                            287

             Muskan v. Ishaan Khan (Sataniya) and Others


          “Conclusions
          33. In view of the above and for the reasons stated above,
          our final conclusions on the principal/core issue, whether
          the High Court would be justified in passing an interim
          order of stay of investigation and/or “no coercive steps
          to be adopted”, during the pendency of the quashing
          petition under Section 482 CrPC and/or under Article 226
          of the Constitution of India and in what circumstances and
          whether the High Court would be justified in passing the
          order of not to arrest the accused or “no coercive steps
          to be adopted” during the investigation or till the final
          report/charge-sheet is filed under Section 173 CrPC, while
          dismissing/disposing of/not entertaining/not quashing the
          criminal proceedings/complaint/FIR in exercise of powers
          under Section 482 CrPC and/or under Article 226 of the
          Constitution of India, our final conclusions are as under:
          33.1 ….
          33.2. Courts would not thwart any investigation into the
          cognizable offences.
          33.3. It is only in cases where no cognizable offence or
          offence of any kind is disclosed in the first information report
          that the Court will not permit an investigation to go on.
          33.4. The power of quashing should be exercised sparingly
          with circumspection, as it has been observed, in the “rarest
          of rare cases” (not to be confused with the formation in
          the context of death penalty).
          33.5. While examining an FIR/complaint, quashing of which
          is sought, the court cannot embark upon an enquiry as to
          the reliability or genuineness or otherwise of the allegations
          made in the FIR/complaint.
          33.6 ….
          33.7. Quashing of a complaint/FIR should be an exception
          rather than an ordinary rule.
          33.8 to 33.11 ….
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                            Supreme Court Reports


             33.12. The first information report is not an encyclopedia
             which must disclose all facts and details relating to the
             offence reported. Therefore, when the investigation by the
             police is in progress, the court should not go into the merits
             of the allegations in the FIR. Police must be permitted
             to complete the investigation. It would be premature to
             pronounce the conclusion based on hazy facts that the
             complaint/FIR does not deserve to be investigated or that
             it amounts to abuse of process of law. After investigation, if
             the investigating officer finds that there is no substance in
             the application made by the complainant, the investigating
             officer may file an appropriate report/summary before the
             learned Magistrate which may be considered by the learned
             Magistrate in accordance with the known procedure.
             33.13 and 33.14 …..
             33.15. When a prayer for quashing the FIR is made by
             the alleged accused and the court when it exercises the
             power under Section 482 CrPC, only has to consider
             whether the allegations in the FIR disclose commission
             of a cognizable offence or not. The court is not required
             to consider on merits whether or not the merits of the
             allegations make out a cognizable offence and the court
             has to permit the investigating agency/police to investigate
             the allegations in the FIR.”
                                                    (emphasis supplied)

26. Further, this Court in the case of State of Telangana v. Habib
    Abdullah Jeelani and Others12 held that:
             “13. There can be no dispute over the proposition that
             inherent power in a matter of quashment of FIR has to
             be exercised sparingly and with caution and when and
             only when such exercise is justified by the test specifically
             laid down in the provision itself. There is no denial of the
             fact that the power under Section 482 CrPC is very wide
             but it needs no special emphasis to state that conferment


12   (2017) 2 SCC 779
[2025] 11 S.C.R.                                                         289

              Muskan v. Ishaan Khan (Sataniya) and Others


           of wide power requires the Court to be more cautious. It
           casts an onerous and more diligent duty on the Court.
           14. In this regard, it would be seemly to reproduce
           a passage from Kurukshetra University [Kurukshetra
           University v. State of Haryana, (1977) 4 SCC 451: 1977
           SCC (Cri) 613] wherein Chandrachud, J. (as his Lordship
           then was) opined thus : (SCC p. 451, para 2)
                “2. It surprises us in the extreme that the
                High Court thought that in the exercise of its
                inherent powers under Section 482 of the Code
                of Criminal Procedure, it could quash a first
                information report. The police had not even
                commenced investigation into the complaint
                filed by the Warden of the University and no
                proceeding at all was pending in any court in
                pursuance of the FIR. It ought to be realised
                that inherent powers do not confer an arbitrary
                jurisdiction on the High Court to act according
                to whim or caprice. That statutory power has
                to be exercised sparingly, with circumspection
                and in the rarest of rare cases.” ”
                                                  (emphasis supplied)

27. We are of the view that the High Court has erred in law by embarking
    upon an enquiry with regard to credibility or otherwise of the allegations
    in the complaints and the FIR. Normally, for quashing an FIR, it
    must be shown that there exists no prime facie case against the
    accused persons. In the present case, from the conjoint reading of
    the complaints and the FIR, it can be seen that prime facie allegations
    of harassment and demand of dowry are made out, despite that the
    High Court quashed the FIR against the private respondents primarily
    on the ground that the earlier two complaints that were filed by the
    appellant did not mention the specific instances that happened on
    22.07.2021 and 27.11.2022 and the same were later on mentioned
    in the FIR only as an afterthought and was a counterblast to the
    legal notice sent by respondent no.1/husband to the appellant as
    she was not coming back to her matrimonial home. This approach
    adopted by the High Court, in our considered opinion, amounts to
    conducting a mini trial.
290                                                   [2025] 11 S.C.R.

                              Supreme Court Reports


28. Accordingly, in our view, the present case warrants interference by
    this Court, and we do so. We hereby set aside the impugned order
    passed by the High Court in Miscellaneous Criminal Case No.10695
    of 2024.
29. The Appeal is, accordingly, allowed. All contentions and defences
    available to the respective parties are kept open which shall be
    considered by the Trial Court on its own merits and in accordance
    with law.

       Result of the case: Appeal allowed.




       †
           Headnotes prepared by: Ankit Gyan