Supreme Court Quashes Proceedings Against Husband’s Relatives in Dowry Harassment Case
(Muppidi Lakshmi Narayana Reddy & Ors. vs. State of Andhra Pradesh & Anr., Criminal Appeal No. ___ of 2025, arising out of SLP (Crl.) No. 2570 of 2018)
In a significant judgment delivered on April 23, 2025, the Supreme Court once again emphasized the need to prevent misuse of Section 498A IPC. The bench, comprising Justice Prashant Kumar Mishra and Justice Ahsanuddin Amanullah, quashed criminal proceedings against three of the husband's relatives — his sister-in-law, her husband, and his father-in-law — citing lack of specific allegations against them.
The case stemmed from a matrimonial dispute where the wife had filed an FIR accusing her husband and his extended family of dowry harassment. However, the Court found that the accusations against the appellants were vague, generalized, and lacked concrete details such as the time, place, or manner of the alleged harassment.
The appellants, who resided separately in Hyderabad, had contended that they were falsely implicated and were not involved in any matrimonial discord. Agreeing with them, the Court observed that sweeping allegations without any substantive evidence cannot be a basis to prosecute distant family members.
The Court drew upon its earlier rulings in Geeta Mehrotra v. State of Uttar Pradesh and the more recent Dara Lakshmi Narayana v. State of Telangana, where it had strongly discouraged the practice of indiscriminately dragging relatives into matrimonial disputes without credible grounds.
Highlighting the human cost of such false implications, the Court noted:
> "Generalized accusations unsupported by specific facts must be nipped in the bud to protect innocent family members from undue harassment."
Concluding that allowing the case to proceed would amount to an abuse of the judicial process, the Supreme Court quashed the criminal case pending before the Special Judicial Magistrate in Guntur.
Thus, the appeal was allowed, bringing much-needed relief to the appellants.
