Supreme Court Highlights Growing Trend Of Dowry Victims Arraigning Relatives Of Husband residing at distant place away from victim

 Insofar as Appellant Nos. 2 to 6 are concerned, we find that they have no connection to the matter at hand and have been dragged into the web of crime without any rhyme or reason. A perusal of the FIR would indicate that no substantial and specific allegations have been made against Appellant Nos. 2 to 6 other than stating that they used to instigate Appellant No. 1 for demanding more dowry. It is also an admitted fact that they never resided with the couple namely Appellant No. 1 and Respondent No. 2 and their children. Appellant Nos. 2 and 3 resided together at Guntakal, Andhra Pradesh. Appellant Nos. 4 to 6 live in Nellore, Bengaluru and Guntur respectively. {Para 24}

25. A mere reference to the names of family members in a criminal case arising out of a matrimonial dispute, without specific allegations indicating their active involvement should be nipped in the bud. It is a well- recognised fact, borne out of judicial experience, that there is often a tendency to implicate all the members of the husband's family when domestic disputes arise out of a matrimonial discord. Such generalised and sweeping accusations unsupported by concrete evidence or particularised allegations cannot form the basis for criminal prosecution. Courts must exercise caution in such cases to prevent misuse of legal provisions and the legal process and avoid unnecessary harassment of innocent family members. In the present case, Appellant Nos. 2 to 6, who are the members of the family of Appellant No. 1 have been living in different cities and have not resided in the matrimonial house of Appellant No. 1 and Respondent No. 2 herein. Hence, they cannot be dragged into criminal prosecution and the same would be an abuse of the process of the law in the absence of specific allegations made against each of them.

 IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 2137 of 2025 

Decided On: 23.04.2025

Muppidi Lakshmi Narayana Reddy and Ors. Vs. The State of Andhra Pradesh and Ors.

Hon'ble Judges/Coram:

Ahsanuddin Amanullah and Prashant Kumar Mishra, JJ.

Author: Prashant Kumar Mishra, J.

Citation: 2025 INSC 562: MANU/SC/0546/2025

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Whether criminal complaint making general allegations is liable to be quashed?

Perusal of the complaint, makes it abundantly clear that the
respondent No.3 has not given the dates on which the reality show “Big
Boss” was aired and viewed by him. The respondent No.3 has also not
given particulars in respect of the indecency and vulgarity alleged by
him. Also the names and particulars of the participants who exhibited
vulgarity are not given. The respondent No.3 has also not mentioned the
names of the persons from whom he has received the complaints. The
respondent No.3 has made ominous/general allegations. On the basis of
these allegations, in our considered view, continuation of investigation
into such FIR would be futile and also it would be abuse of process of
law. In the above circumstances, we allow the petition in terms of
prayer clause (a). Consequently, the complaint dated 4th October, 2008
and FIR No.34 of 2008 registered with Andheri Police Station against the
petitioners is quashed and set-aside.
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CRIMINAL APPELLATE JURISDICTION
CRIMINAL WRIT PETITION NO.2170 OF 2008
Endemol India Pvt. Ltd. and ors. v The State of Maharashtra and anr. 

 CORAM : RANJIT MORE &
 SMT.SADHANA JADHAV, JJ.
 DATE : 21st SEPTEMBER, 2017.

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