Supreme Court restores FIR in dowry-cruelty case, holds High Court erred by conducting 'mini-trial' while quashing proceedings

A bench of Justices Sanjay Karol and Prashant Kumar Mishra heard the criminal appeal against a High Court order that had quashed FIR No.35 of 2024 registered at Police Station Alot, Ratlam, under Section 498A IPC and Sections 3 and 4 of the Dowry Prohibition Act. The appeal challenged the Madhya Pradesh High Court’s decision to quash proceedings against five private respondents primarily on the ground that two specific incidents later narrated in the FIR were not mentioned in earlier complaints.

The Supreme Court allowed the appeal, set aside the High Court’s order dated 19.07.2024 and directed that the criminal proceedings be revived so that investigation and trial could proceed. The Court held that the High Court had impermissibly “embarked upon an enquiry with regard to credibility” of allegations and had effectively conducted a mini-trial while deciding a quashing petition under Section 482 CrPC. The Court recorded established principles that the power to quash must be exercised sparingly and that a court, when considering quashing, “only has to consider whether the allegations in the FIR disclose commission of a cognizable offence or not.” The Court, in its reasoning, observed: The Court reiterated the settled law that quashing was an exception and that police should generally be permitted to complete investigation.

Background The appellant, Muskan, alleged that she was married to respondent No.1 on 20.11.2020 and that after initial cordiality she faced continuous cruelty and taunts that her father had given no dowry. The complaints dated 22.01.2023 and 23.01.2023 lodged before the Women’s Cell recited ongoing harassment, restrictions, denial of food and communication, and repeated demands for dowry in varying forms. The FIR lodged on 28.01.2024 added two specific incidents: an episode on 22.07.2021 in which she was allegedly slapped and abused, and a demand on 27.11.2022 that she procure Rs. 50 lakhs, followed by her ouster with her infant son. The High Court quashed the FIR after observing that the earlier complaints “there has not been a whisper of the events of harassment on 22.07.2021 and 27.11.2022” and that “It manifests that the alleged incidents … are afterthought,” treating that omission as a strong factor justifying quashment.

On appeal, the State and the Amicus Curiae for unrepresented private respondents argued legal principles requiring cautious exercise of inherent powers under Section 482 CrPC and relied on precedents such as Bhajan Lal and Neeharika Infrastructure. The Supreme Court examined authorities including Bhajan Lal, Daxaben, Neeharika and others, and held that the High Court had gone beyond permissible limits by evaluating the veracity of allegations at the quashing stage. The Court found that, on a conjoint reading of the complaints and FIR, prima facie allegations of harassment and dowry demand were made out and therefore the FIR deserved investigation rather than quashment. The appeal was allowed, the impugned order set aside, and the parties’ substantive contentions were left open for the trial court or investigating agency to examine on merits in accordance with law. The Court noted that respondent Nos.1–5 had not entered appearance before the Supreme Court and that Mr. Prakhar Srivastava had been appointed as Amicus Curiae to assist the Court pro bono.

Case Details: Case No.: Criminal Appeal No. 4752 of 2025 (Arising out of S.L.P. (Criminal) No.1531 of 2025) Case Title: Muskan v. Ishaan Khan (Sataniya) and Others Appearances: For the Petitioner(s): (Name of counsel for the appellant not specified in the judgment) For the Respondent(s): Mr. Prakhar Srivastava, Amicus Curiae (appointed pro bono) ; Counsel for State of Madhya Pradesh (name not specified in the judgment)