Case Name: CHARUL SHUKLA VS. STATE OF U.P. & OTHERS
Petition Number: Special Leave Petition (Criminal) Nos. 555 and 609 of 2024
Neutral Citation: 2026 INSC 297
Date of Judgement: 25.03.2026
Coram: HON’BLE MR JUSTICE B.V. NAGARATHNA & HON’BLE MR JUSTICE UJJAL BHUYAN
INTRODUCTION
This criminal appeal by Special Leave Petition examined whether vague and delayed allegations of matrimonial cruelty and dowry demands, lacking corroborative evidence, could justify the continuation of criminal proceedings against a husband’s relatives. The case primarily addresses the growing concern over the misuse of Section 498A IPC as a tool for personal vendetta in matrimonial disputes. The appellants sought to quash an FIR and subsequent chargesheet alleging cruelty, assault, and sexual misconduct.
FACTS
In the present matter, the complainant alleged that from the inception of her marriage in 2017, her husband and his family frequently demanded dowry. Due to financial constraints, her family was unable to fulfil these demands, which allegedly led to her harassment and torture by the accused/appellants.
She further claimed that during her pregnancy in 2017, the appellants and her husband assaulted her, leading to a miscarriage. Later in that year, her father-in-law allegedly engaged in sexually inappropriate conduct with her. Finally, she asserted that in 2023, the appellants assaulted her and compelled her to leave the matrimonial home.
Subsequently, the complainant lodged an FIR in 2023. Following the investigation, a chargesheet was filed. Cognisance was taken under Section 498A and 323 IPC, and Sections 3 and 4 of the Dowry Prohibition Act,1961 against the appellants, and additional charges under Section 354 IPC were filed against the father-in-law. However, the investigating officer dropped the charges under Section 313 IPC. Aggrieved by the High Court’s decision to dismiss their plea for quashing the criminal case, the appellant appealed before the Hon’ble Supreme Court.
ISSUES
- Whether the criminal proceedings initiated against the sister-in-law and parents-in-law be quashed?
- Whether the unexplained delay of nearly seven years in lodging the FIR and the vague, omnibus nature of the allegations vitiate the prosecution’s case against the appellants?
SUBMISSION BY THE PARTIES
The appellants contended that the FIR consisted of generalised accusations lacking specific dates, times, or locations, particularly regarding the alleged dowry demands and physical assault. They highlighted a significant delay of over six years and seven months between the marriage and the filing of the FIR, casting doubt on the veracity of the claims. The parents-in-law, both senior citizens, argued the case was a counterblast intended to harass them long after the complainant had deserted her husband.
JUDGEMENT AND ANALYSIS
The Hon’ble Bench analysed whether the allegations in the FIR and the subsequent chargesheet were sufficient to proceed against the appellants, keeping in mind the significant delay in filing the complaint. The Court noted that the FIR was lodged more than six years and seven months after the initial allegations of dowry demand and harassment. The complainant failed to provide any sufficient cause for this delay.
The Court noted that citizens who allege the commission of an offence should pursue their remedies in real time to achieve the ends of justice, as vigilantibus non dormientibus jura subveniunt, meaning that law protects those who are vigilant about their rights.
The Court further explained that, in matrimonial criminal disputes, delay assumes particular significance, as such cases are often based on personal allegations and frequently lack sufficient evidence to support or rebut the claims and counterclaims. The Court reiterated that the allegations were vague and omnibus and unsupported by cogent evidence.
The Court reaffirmed the principle enunciated in Dara Lakshmi Narayana vs. State of Telangana, that 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.”
Upon reviewing the chargesheet, the court observed that the medical report did not have any record of injury corresponding to, or supporting, the complainant’s allegation of miscarriage. Similarly, the allegations of sexual inappropriate conduct against the father-in-law lacked specific details of the alleged ‘obscene acts’ and had no material support. The court also noted that, despite due service of notice, the complainant failed to appear in the present proceedings and drew an adverse inference regarding her lack of interest in contesting the appeal.
CONCLUSION
The Hon’ble Supreme Court concluded that the allegations against the appellants were maliciously instituted with an ulterior motive and lacked sufficient evidentiary backing. The Court set aside the High Court’s order and quashed the FIR, the chargesheet and the criminal case against the appellants. The Court quashed the proceedings, holding that an unexplained delay of nearly seven years substantially undermined the credibility of the prosecution’s case. Further, an emphasis was made by the Hon’ble Court that an unexplained delay in instituting criminal proceedings may prove fatal in matrimonial disputes.
