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Supreme Court of India 2023-08-31 allowed

Abhishek vs State of Madhya Pradesh

Bench: 3 — Aniruddha Bose, Sanjay Kumar, S.V.N. Bhatti

In Brief

In this criminal appeal, a wife (Bhawna) filed dowry harassment charges against her in-laws—her mother-in-law and two brothers-in-law. The Supreme Court held that the allegations were entirely general and lacked specific details about how or when the in-laws harassed her. Critical inconsistencies weakened the case: she admitted her jewellery was with her husband (not taken by in-laws), did not file a complaint for four years after leaving, and the in-laws lived in different cities with minimal contact. The Court ruled the allegations were so farfetched and improbable that no prudent person could conclude there were sufficient grounds to prosecute. The Court allowed the appeal and quashed the FIR and proceedings, emphasizing the need to prevent misuse of Section 498A IPC in matrimonial disputes.

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Criminal Procedure Section 498A IPC Dowry Harassment Matrimonial Disputes Abuse of Process Quashing of FIR Inherent Powers of High Court

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