Brief Facts
- The complainant married Niraj Mahendrabhai Patel in 2002.
- A property dispute arose between the complainant’s husband and his father. The complainant’s husband filed a civil suit in 2013.
- The complainant lodged an FIR in 2013, alleging harassment, deprivation of property rights, and physical and mental abuse. She alleged dowry demands and threats by her stepmother-in-law, stepbrother-in-law, father-in-law, and a Munim.
- A similar complaint under the Domestic Violence Act was dismissed in 2019 as unfounded.
- The High Court upheld the validity of the FIR, prompting the appellants to approach the Supreme Court.
Issues
- Whether the allegations in the FIR constituted a prima facie case u/s 498A, 323, 504, 506 IPC?
- Whether the courts at Jalna had jurisdiction to entertain the complaint?
- Whether the FIR was a misuse of criminal law to further civil disputes?
Held
- The Supreme Court overturned the High Court’s dismissal of the quashing petition, holding that the complaint lacked specificity and was rooted in civil disputes over property. Supreme Court also took note of the fact that the FIR does not make any allegation against the husband and the Complainant merely implicates her in-laws.
- The Court held that allegations lacking material specifics and dates do not constitute a prima facie case under criminal law. The FIR was deemed an abuse of the process of law, filed to advance interests in a property dispute.
- The Court reiterated that criminal proceedings could be quashed even after filing a chargesheet if the allegations are baseless.
Relevant Para Nos.
- 11,14,16