The Nagpur Bench of the Bombay High Court recently highlighted a concerning trend in matrimonial dispute cases—wives filing police complaints against all members of the husband's family, using Section 498A of the IPC as a tool for settling personal scores. The court made these remarks while partially allowing a plea to quash a criminal case involving allegations of domestic cruelty and dowry harassment.
A Division Bench comprising Justices Anil Kilor and Pravin S. Patil delivered the ruling on June 9, 2025, in Criminal Application No. 1565 of 2023, where the applicants sought the quashing of FIR registered under Sections 498A, 323, 504, 506 read with Section 34 of the IPC and Section 4 of the Dowry Prohibition Act.
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The case originated from a complaint filed on August 30, 2023, by the wife, who alleged mental and physical abuse by her husband and his family after their marriage on June 2, 2014. She accused them of insulting her, calling her the “daughter of a beggar,” and subjecting her to ill-treatment over dowry.
“Nowadays in proceedings arising out of matrimonial discord, there is a tendency of wife to implicate the husband and his family members in the web of crime. The police complaint is considered in such matters as the only panacea to teach a lesson to the family members of the husband,” the court observed.
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The husband argued that the FIR was motivated by personal vendetta and cited a pending divorce case filed on June 29, 2022. He also stated that the wife had left their home without informing anyone, prompting a missing complaint on June 13, 2022.
The court took note that the wife's core allegations were mainly directed at her husband, particularly regarding physical abuse and suspicions over her character. The court concluded that these specific grievances warranted a continuation of legal proceedings against him.
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“There is a serious dispute between husband and wife, and there is reason to believe the allegations against the husband. At this stage, they cannot be denied,” the judges stated.
However, the allegations against the remaining family members—parents-in-law, sisters-in-law, and others—were found to be vague and lacking specifics such as date, time, and nature of harassment.
“In support of these allegations, no details are given. Hence, all allegations against relatives of the husband are to be treated as vague and general in nature,” the bench said.
Consequently, the High Court quashed the proceedings against the husband’s relatives, concluding that there was no prima facie case against them.
Case Title: SDA vs State of Maharashtra (Criminal Application 1565 of 2023)