Supreme Court Quashes FIR Alleging Harassment by Extended Relatives in Matrimonial Dispute: “The Term ‘Relative’ Under Section 498-A IPC Refers to Closely Connected Individuals; Distant Relatives Require Clear Evidence of Involvement”

Court’s Decision

1. Accused No.5: The Supreme Court quashed the FIR and all related proceedings against Accused No.5 (wife of Accused No.6). The Court reasoned that the allegations against her were vague, exaggerated, and lacked specificity. It held that forcing her to face trial based on these accusations would constitute an abuse of the judicial process.
2. Accused No.6: The Court upheld the High Court’s decision to quash the proceedings against Accused No.6 (husband of Accused No.5), finding no specific allegations connecting him to the offenses under Sections 406, 498-A, 420, and 120-B IPC.
3. Complainant’s Appeal: The complainant’s appeal, seeking restoration of proceedings against Accused No.6, was dismissed. The Court found no legal basis to interfere with the High Court’s decision.

Facts of the Case

1. Marriage and Subsequent Events:
   • The complainant’s daughter married the primary accused, Amit Sharma, on February 23, 2019. Amit Sharma left for Canada shortly after the marriage, leaving his wife in her matrimonial home in Jalandhar, Punjab.
   • She later joined him in Canada in December 2019, but the couple’s relationship soured, leading Amit Sharma to file for divorce in Canada in September 2020.
2. FIR and Allegations:
   • The complainant (father of the wife) lodged an FIR on December 3, 2020, alleging harassment and fraudulent acts by multiple individuals, including distant relatives of his son-in-law.
   • Accused Nos.5 and 6 (a distant cousin and his wife) were accused of demanding money and being involved in a conspiracy to mislead his daughter regarding property ownership.
3. High Court’s Decision:
   • The High Court quashed the FIR against Accused No.6 due to the absence of specific allegations but refused to grant similar relief to Accused No.5, leading to the appeals in the Supreme Court.

Legal Issues

1. Whether the FIR against Accused No.5 should be quashed on grounds of vague and exaggerated allegations.
2. Whether vague allegations can justify framing charges under IPC Sections 406, 498-A, 420, and 120-B.
3. Whether the High Court erred in denying relief to Accused No.5 despite granting relief to Accused No.6 based on similar allegations.

Arguments by Accused No.5 (Petitioner)

• Vague Allegations: Accused No.5 argued that the FIR contained generalized allegations without any specific evidence of her involvement in the alleged offenses.
• Residence in Another City: She highlighted that she and her husband (Accused No.6) resided in Mohali, Punjab, and were not directly involved in the complainant’s daughter’s marital life in Jalandhar.
• Misuse of Law: The petitioner contended that the FIR was filed with a malicious intent to harass extended family members and exert pressure on the main accused (the complainant’s son-in-law).

Arguments by the Complainant (Respondent)

• Specific Allegations: The complainant insisted that there were specific allegations against Accused No.5, including her involvement in extortion and conspiracy.
• Challan Filed: The complainant argued that since a chargesheet had already been filed in the trial court, the petitioner could raise her defense during the trial instead of seeking quashing of proceedings.

Analysis of the Law

1. Section 498-A IPC (Cruelty):
   • The Court emphasized that the term “relative” under Section 498-A IPC refers to individuals closely connected to the victim, such as parents or siblings. Distant relatives living in another city do not fall under this ambit unless there is clear evidence of active involvement in cruelty.
2. Precedents Considered:
   • Preeti Gupta v. State of Jharkhand (2010): Warned against over-implication of extended family members in matrimonial disputes and the potential misuse of Section 498-A IPC.
   • Geeta Mehrotra v. State of U.P. (2012): Held that vague and generalized allegations against family members, especially those living separately, do not warrant criminal proceedings.
   • State of Haryana v. Bhajan Lal (1992): Identified categories of cases where inherent powers under Section 482 Cr.P.C. can be used to quash proceedings, including cases where allegations are inherently improbable.
3. Principles Applied:
   • The Court observed that the allegations against Accused Nos.5 and 6 were general and lacked specific details, amounting to over-implication to harass distant relatives.
   • It reiterated that criminal law cannot be used as a tool for settling personal scores in matrimonial disputes.

Court’s Reasoning

1. Vague Allegations:
   • The FIR and chargesheet contained only broad and non-specific accusations against Accused Nos.5 and 6. The Court found no evidence connecting them to the alleged offenses.
2. Residence in Another City:
   • Accused Nos.5 and 6 resided in Mohali, while the complainant’s daughter lived in Jalandhar. There was no evidence of their direct involvement in the alleged acts of cruelty or conspiracy.
3. Misuse of Law:
   • The Court criticized the tendency to implicate extended family members in matrimonial disputes without substantial evidence, noting that this practice burdens the judicial system and causes undue harassment.

Conclusion

• Relief for Accused No.5: The Supreme Court quashed the FIR and all related proceedings against Accused No.5, stating that making her face trial based on such vague and exaggerated allegations would amount to an abuse of process.
• Dismissal of Complainant’s Appeal: The Court dismissed the complainant’s appeal, upholding the High Court’s decision to quash proceedings against Accused No.6.

Implications

1. Prevention of Abuse: This judgment serves as a caution against the misuse of legal provisions in matrimonial disputes, especially to harass distant relatives without substantive evidence.
2. Judicial Scrutiny: Courts must critically evaluate allegations to prevent over-implication and ensure that criminal proceedings are not weaponized.
3. Clarity in Family Law: The ruling clarifies the scope of “relatives” under Section 498-A IPC, emphasizing the need for direct involvement in alleged offenses for criminal liability to arise.

This judgment underscores the importance of scrutinizing allegations in matrimonial disputes to protect innocent individuals from harassment and uphold the integrity of the judicial process.

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