Supreme Court Quashes 498-A, 377, 506 IPC FIR Against In-Laws, Cites Bhajan Lal Guidelines on Abuse of Process
Case Name: Sanjay D. Jain & Ors. v. State of Maharashtra & Ors.
Date of Judgment: September 26, 2025
Citation: 2025 INSC 1168, Criminal Appeal (arising out of SLP (Crl.) No. 12584 of 2024)
Bench: Hon’ble Chief Justice B.R. Gavai, Hon’ble Mr. Justice K. Vinod Chandran, and Hon’ble Mr. Justice Atul S. Chandurkar
Held: The Supreme Court allowed the appeal and quashed criminal proceedings against the appellants—father-in-law, mother-in-law, and sister-in-law of the complainant—registered under Sections 498-A, 377, and 506 read with Section 34 IPC. It held that the FIR contained only vague and omnibus allegations of dowry demands and cruelty without particulars, which did not constitute a prima facie case under Section 498-A. Further, allegations of unnatural sex and criminal intimidation were directed only against the complainant’s husband, not the appellants. The Court reiterated that continuation of proceedings against relatives on such vague accusations amounts to abuse of process and falls within the parameters laid down in State of Haryana v. Bhajan Lal (1992 Supp (1) SCC 335).
Summary: The complainant married Piyush Jain in July 2021 and alleged that her in-laws demanded dowry in the form of clothes and jewellery, while her husband subjected her to unnatural sex and threats. On this basis, FIR No.20/2022 was registered under Section 498-A IPC and later Sections 377 and 506 were added. The appellants moved for quashing under Section 482 CrPC, which was rejected by the Bombay High Court (Nagpur Bench) in March 2024, holding that prima facie allegations existed. On appeal, the Supreme Court observed that the FIR referred only to a phone call from the mother-in-law demanding clothes, with no further details of cruelty amounting to the ingredients of Section 498-A. General statements without specifics cannot ground criminal proceedings. As to Sections 377 and 506, there were no allegations against the in-laws at all, with the complaint clearly pointing only to the husband. The Court stressed that vague and omnibus allegations against in-laws have been consistently discouraged, citing Digambar v. State of Maharashtra (2024 INSC 1019).
Decision: The Supreme Court quashed the FIR and final report against the in-laws under Sections 498-A, 377, and 506 IPC, clarifying that proceedings against the husband (accused no.1) would continue on their own merits. The appeal was allowed, with no order as to costs.