Bombay HC quashes FIR under 498A & 306 IPC against distant in-laws citing vague allegations. Landmark ruling on misuse of dowry law : Santosh Ambadas Padmagirwar Vs State of Maharastra

 

📅 Date of Judgment: 18th December 2024

🏛️ Coram: Hon’ble Justices Avinash G. Gharote and Abhay J. Mantri
📍 Court: Bombay High Court, Nagpur Bench

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📝 Key Facts:

• Deceased Vaishali was married to Applicant No.1 – Santosh Padmagirwar.

• She committed suicide on 28.01.2017 by allegedly consuming tablets.

• FIR lodged by her father on 03.02.2017 alleged cruelty and dowry harassment against Santosh and his distant relatives (married sisters and brother-in-law).

• Offences alleged: Sections 498A, 306 r/w 34 IPC.

• The prosecution continued against all family members including those not residing with the deceased and who had been living separately in other cities.

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⚖️ Issues Raised:

Whether distant relatives (in-laws) who lived separately from the deceased and her husband, and against whom only vague and general allegations were made, can be subjected to criminal trial under Sections 498A and 306 IPC?

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🧵 Court’s Reasoning:

1. No Specific Allegations or Role Attributed:
   The FIR and charge sheet lacked specific instances of cruelty or abetment by applicants Nos. 2 to 7 (distant relatives).

2. Distant and Married Relatives Living Separately:
   The relatives had been living separately in their matrimonial homes since 1974–2007. Mere familial connection doesn't justify prosecution.

3. Statements were Omnibus and Stereotyped:
   Witness statements were generalized, repetitive, and lacked detail. No time, place, or incident was clearly described.

4. Guiding Precedents Applied:

   • Dara Lakshmi Narayana v. State of Telangana (2024 SCC OnLine SC 3682):
     Courts must curb the practice of implicating entire families without concrete allegations.

   • Geeta Mehrotra v. State of U.P. (2012) 10 SCC 741:
     Casual references to names without specific accusations cannot lead to criminal prosecution.

   • Kahkashan Kausar v. State of Bihar (2022) 6 SCC 599:
     Distant relatives must not be prosecuted based on omnibus allegations without concrete evidence.

   • Nipun Aneja v. State of U.P. (2024):
     Reiterated principles on Section 306 IPC and the misuse of criminal process.

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🔍 Legal Principles Laid Down:

• Criminal law cannot be invoked casually against distant relatives based on vague allegations.

• Section 482 CrPC empowers courts to quash such proceedings to prevent abuse of the legal process.

• Courts must ensure that emotional and social implications of matrimonial discord do not lead to unjustified harassment of innocent family members.

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🧾 Final Verdict:

• FIR and charge sheet quashed against applicants Nos. 2 to 7 under Sections 498A and 306 IPC.

• The court held that continuing proceedings against them would amount to abuse of the judicial process.

• Application partly allowed — application against husband (Applicant No.1) was not pressed.

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🖊️ Conclusion:

This judgment stands as an important reaffirmation of the need for specific, evidence-backed allegations in criminal prosecutions, especially in sensitive matrimonial disputes. It strongly discourages blanket accusations against in-laws and distant relatives, and promotes a just, cautious, and evidence-oriented approach by both investigating agencies and trial courts.

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