Relatives of Husband Cannot Be Dragged Into Dowry or Domestic Violence Cases Without Specific Allegations of Their Active Role
Case Name: Arti Mehta & Ors. v. The State of Madhya Pradesh & Anr. with Arti Mehta & Ors. v. Sapna Dhakad
Citation: 2026 INSC 533
Date of Judgment/Order: 25 May 2026
Bench: Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh
Held: The Supreme Court held that in matrimonial disputes, relatives of the husband cannot be prosecuted under Section 498A IPC, Sections 3 and 4 of the Dowry Prohibition Act, or proceeded against under the Domestic Violence Act merely because they are related to the husband or allegedly supported him. The Court clarified that criminal liability requires specific, distinct and prima facie allegations showing active participation in cruelty, harassment, dowry demand or domestic violence. General statements that family members “used to harass”, “supported the husband”, “failed to intervene”, or “asked the wife to adjust” are not enough to continue criminal proceedings in the absence of specific dates, incidents, overt acts or individual roles.
Summary: The dispute arose out of matrimonial discord between Sapna Dhakad and her husband Divyaraj Dhakad. The complainant lodged FIR No. 41/2023 at Police Station Guna, Madhya Pradesh under Sections 498A/34 IPC and Sections 3 and 4 of the Dowry Prohibition Act against the husband and his relatives, namely Arti Mehta, Shrivati Bai Dhakad, Manisha Dhakad and Vikram Dhakad. She also filed proceedings under Section 12 of the Domestic Violence Act against them. The High Court refused to quash both proceedings. Before the Supreme Court, the husband’s relatives contended that the allegations against them were vague, omnibus and based only on their relationship with the husband. The Supreme Court examined the FIR, the DV complaint and the complainant’s own divorce petition and found that the main allegations of assault, abuse, neglect, threats, restriction of movement, suspicion of another relationship and denial of marital companionship were directed against the husband. As against the appellants, the allegations were broad and collective, without any specific incident or individual overt act showing cruelty, dowry demand or domestic violence. The Court cautioned that while genuine domestic violence cases must be protected, criminal law cannot be used to implicate every family member of the spouse on sweeping allegations arising from matrimonial bitterness.
Decision: The Supreme Court allowed the appeals, set aside the High Court’s orders dated 21.11.2024 in Misc. Criminal Case No. 14615 of 2023 and Misc. Criminal Case No. 20269 of 2023, and quashed FIR/Crime No. 41/2023 dated 13.01.2023 registered at Police Station Guna, Madhya Pradesh under Sections 498A/34 IPC and Sections 3 and 4 of the Dowry Prohibition Act, together with all consequential proceedings including the charge-sheet, qua the appellants Arti Mehta, Shrivati Bai Dhakad, Manisha Dhakad and Vikram Dhakad. The Court also quashed D.V. Complaint No. 1752 of 2023 pending before the Judicial Magistrate First Class, Guna, qua the said appellants. The Court clarified that the observations were confined only to the appellants and would not affect proceedings against the husband or any other accused, and that the trial court may still exercise power under Section 319 CrPC if evidence later emerges against the appellants. Pending applications were disposed of.