Supreme Court Dismisses Criminal Case Against Man and His Family, Finding FIR Filed with Hidden Intent After Husband Chose Divorce.

In a situation of marital conflict, where the wife filed a First Information Report (FIR) against her husband and his family just two months after he submitted a divorce petition, the Supreme Court dismissed the criminal case due to the vague and general nature of the woman’s allegations. This appeal was based on a decision from the Allahabad High Court, which had rejected the Appellants’ request to quash the chargesheet and the order of cognizance in a case involving Sections 498A, 504, and 506 of the Indian Penal Code, 1860, along with Sections 3 and 4 of the Dowry Prohibition Act, 1961. The Division Bench, consisting of Justice B. V. Nagarathna and Justice Satish Chandra Sharma, noted that witness statements indicated the accusations were broad and lacked specific details.

AOR Ram Lal Roy represented the Appellants, while AOR Sakshi Kakkar represented the Respondents. The marriage between the Appellant-husband and Respondent-wife took place in 2016. However, they began living apart, leading the husband to seek a divorce under Section 13 of the Hindu Marriage Act, 1955. After the divorce petition was filed, the wife accused her husband, brother-in-law, mother-in-law, and father-in-law in an FIR. The Appellants then approached the High Court with a petition under Section 482 of the CrPC, which was dismissed. The Supreme Court appeal stemmed from this order, and the Court had previously granted temporary relief, staying the trial court proceedings.

The Bench stated, “After reviewing the previous judgments from this Court, and noting that the initial FIR claimed rape but no charge-sheet was created for that charge, along with the absence of a protest petition later, this Court believes that the FIR is frivolous and appears to have been filed with a hidden agenda, especially since the husband had already filed for divorce on 17.06.2021, well before the FIR was submitted against the family members.” Therefore, the Bench granted the appeal and dismissed the FIR and the charge sheet.

Cause Title: X v. State of Uttar Pradesh & Anr. (Neutral Citation: 2025 INSC 203)
Appearance:
Appellants: AOR Ram Lal Roy
Respondents: AOR Sakshi Kakkar, Advocate Puneet Bindra, AOR Anas Tanwir, Advocates Sonal Kushwah, Suryansh Kishan Razdan, Ebad Ur Rahman, Zainab Shaikh