In-Laws Cannot Be Dragged Into Dowry Case on Omnibus Allegations: Supreme Court Quashes FIR

The complainant married the appellants' son in February 2021 and, after he was transferred to Siliguri, lived with the appellants (para 3). After she left the matrimonial home, her FIR of 21 November 2023 alleged dowry taunts and demands including a four-wheeler, neglect during pregnancy, and that the first appellant and her husband forced her to sign a declaration that her streedhan had been returned (paras 4-5). A chargesheet under Sections 498A, 406, 506 and 323 IPC and Sections 3 and 4 of the Dowry Prohibition Act followed (para 6). The Calcutta High Court quashed only the Section 323 charge (paras 2, 8).

Taking each surviving charge, the Court found no material that the appellants caused grave injury to her life, limb or health, or harassed her for property or valuable security, as Section 498A requires (paras 19-20). The dowry allegations of ₹5 lakh and a four-wheeler gave no particulars of the demands, occasions or witnesses, and the investigation surfaced nothing beyond her allegations (para 21). For Section 406, the investigation did not reveal what property was entrusted or whether it was misappropriated; the allegations were "vague and omnibus" (para 23). For Section 506, the only material on the coerced declaration was her own complaint and her parents' Section 161 statements (para 25). Under Arti Mehta, allegations against each relative must be specific and supported by prima facie material, and Geddam Jhansi warns that criminalising domestic disputes without specific allegations can harm the institution of family (paras 16-17). As no overt act was attributed to either appellant, the High Court should have quashed the whole case against them (paras 26, 28).