Supreme Court Restores 498A & Dowry Act Prosecution; Holds High Court Conducted Impermissible Mini Trial Under Section 482 CrPC

Case Name: Muskan v. Ishaan Khan (Sataniya) & Others
Citation: 2025 INSC 1287
Date of Judgment/Order: 06 November 2025
Bench: Sanjay Karol, J.; Prashant Kumar Mishra, J.

Held: The Supreme Court held that the High Court erred in quashing FIR No. 35/2024 under Section 498A IPC and Sections 3 and 4 of the Dowry Prohibition Act by conducting an impermissible “mini trial” and scrutinising inconsistencies between prior complaints and the FIR. The Court ruled that the FIR contained clear prima facie allegations of cruelty, dowry demands, physical assault, and ouster from the matrimonial home, which could not be dismissed merely because earlier complaints did not mention two specific incidents. It reiterated that contradictions or omissions are matters for trial, not quashing, and that the High Court exceeded the narrow parameters of Section 482 CrPC by assessing the credibility of allegations instead of determining whether a cognizable offence was disclosed.

Summary: The appellant married Respondent No.1 in November 2020 and soon faced severe dowry-related harassment, deprivation of food, confinement, verbal abuse, and physical assault from her husband and his family. Though her initial complaints to the Women’s Cell in January 2023 narrated sustained cruelty, her detailed FIR in January 2024 additionally mentioned two specific incidents dated 22 July 2021 and 27 November 2022, including a demand for ₹50 lakhs to fund her husband’s medical examinations and her subsequent ouster from the matrimonial home. The High Court quashed the FIR, holding that the additional incidents were afterthoughts and a counterblast to a legal notice issued by the husband. Before the Supreme Court, the State argued that omissions in earlier complaints do not negate later allegations of dowry harassment, while the amicus for the respondents contended that the FIR was vague and delayed. Examining the complaints and FIR together, the Court held that they cumulatively disclosed a clear pattern of cruelty and dowry demand, and that the High Court had improperly evaluated the truthfulness of allegations by comparing documents—an exercise forbidden at the quashing stage. Reiterating the principles in Bhajan Lal, Neeharika Infrastructure, Aryan Singh, and Daxaben, the Court stressed that quashing is an exception and that FIRs are not encyclopedias required to narrate every detail.

Decision: The Supreme Court set aside the High Court’s order quashing the FIR and restored all criminal proceedings against the respondents. It held that the matter must proceed to investigation and trial, where all factual defences remain open to the parties. The appeal was allowed, and the case remanded for continuation of prosecution strictly in accordance with law. All pending applications were disposed of.