
‘Omnibus Allegations': SC Quashes Dowry Case Against Sister-In-Law, Husband, And Father-In-Law
LawBeat
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The Supreme Court ruled that the dowry harassment complaint lacked specific allegations and cited past precedents warning against indiscriminately involving the husband's relatives
The Supreme Court, on 23 April 2025, quashed a dowry harassment complaint filed by a woman against her sister-in-law, her husband, and her father-in-law, finding the allegations vague and lacking in specific instances of wrongdoing.
A bench comprising Justices Ahsanuddin Amanullah and Prashant Kumar Mishra allowed the appeal filed by Muppidi Lakshmi Narayana Reddy and others, challenging a High Court decision that had refused to quash the proceedings against them. The appellants included a housewife, her husband, who is a software engineer, and her father-in-law, a central government employee.
The bench noted the general nature of the complaint, which stated that although the appellants resided in Hyderabad, they used to visit Guntur, and during such visits, they allegedly instigated the complainant's husband and his parents, joining them in demanding dowry. The complaint further alleged that the sister-in-law demanded Rs 5,00,000 and taunted the complainant, claiming that had her husband married someone else, he could have received Rs 10 crore as dowry.
'There is no allegation of any physical torture being perpetrated by the present appellants. The allegation is only of taunting and the statement that they are highly placed, having political influence and connections with Ministers, and that they instigated the husband and her in-laws to pressurise the de facto complainant to obtain additional dowry," the court observed.
The bench further noted that there was no dispute regarding the appellants' residence in Hyderabad, while the de facto complainant resided at her marital home in Guntur. Moreover, the complaint did not specify any particular date on which the appellants allegedly visited Guntur and participated in the alleged dowry demands.
Geeta Mehrotra & Anr Vs State of Uttar Pradesh & Anr (2012) has deprecated the practice involving the relatives of the husband for the offence under Section 498A IPC and Section 4 of Dowry Prohibition Act, 1961," the bench noted.
'In a recent judgment in the matter of Dara Lakshmi Narayana & Ors Vs State of Telangana & Anr (2024), this court has again reiterated and deprecated the practice of involving the relatives of the husband in dowry-related matters," it added.
In the current case too, the court highlighted, 'It was an admitted position that the appellants were residing at Hyderabad, whereas the de-facto complainant stayed in her marital house at Guntur at the relevant point of time. She was presently staying in the USA."
'There is an omnibus allegation against the appellants that they too used to demand dowry or instigate the husband and in-laws who are not before us, in demanding dowry," the bench noted.
Based on these observations, the court concluded, 'We are of the view, having relied on this court's previous decisions in Geeta Mehrotra and Dara Lakshmi Narayana, the present criminal case against the appellants deserves to be quashed."
The facts of the case date back to May 24, 2014, when the de-facto complainant married Challa Poornananda Reddy in Guntur. Within five months, she left the marital home to reside with her parents. After repeated attempts at reconciliation, she lodged a police complaint on February 13, 2016. However, following intervention from elders, both parties arrived at a compromise in April 2015, leading to the withdrawal of all proceedings.
Subsequently, the complainant moved to the US without informing her husband or his family. Her husband filed a divorce petition on June 21, 2016. As a counterblast, she filed an FIR implicating six individuals, including the appellants.
The appellants maintained that they had no role in the dispute. They emphasised that accused no. 4 was a housewife, no. 5 a software engineer, and no. 6 a government employee — all living in Hyderabad, far from the alleged site of harassment.
Despite these submissions, the high court had earlier dismissed the quashing plea, holding that allegations had been made against the appellants and required a full trial.
First Published:
April 24, 2025, 16:08 IST

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