Supreme Court Reiterates High Court’s Power to Quash FIR Even After Charge-Sheet Filing If Proceedings Are an Abuse of Judicial Process, Quashes FIR Under Section 498-A

Court’s Decision:
The Supreme Court allowed the appeals filed by Shaileshbhai Ranchhodbhai Patel and another appellant, quashing an FIR and subsequent criminal proceedings initiated under Section 498-A of the Indian Penal Code (IPC). The Court invoked its powers under Article 142 of the Constitution to bring a quietus to the long-standing matrimonial dispute between the private parties. Despite the charge-sheet being filed, the Court found that continuation of the proceedings would be an abuse of the legal process.

Facts of the Case:
The appellants, who are the complainant’s parents-in-law and husband, sought to quash an FIR registered in 2002 under Section 498-A at the J.P. Road Police Station, Vadodara, Gujarat. The complainant and the appellant husband had since obtained a mutual divorce in 2004, and the complainant remarried and started a new life. Despite being served notice, the complainant did not appear in court to contest the appeals.

Issues:
The central issue was whether the FIR and the criminal proceedings should be quashed despite the filing of a charge-sheet under Section 173(2) of the Criminal Procedure Code (CrPC), based on the facts that the matrimonial dispute had been resolved and the complainant had moved on with her life.

Court’s Reasoning:
The Court reiterated that the High Court has the power to quash an FIR even after a charge-sheet has been filed, provided that the FIR and charge-sheet, even if accepted as true, do not disclose any offence or that continuation of the proceedings would be an abuse of the judicial process. The Court referred to previous rulings, including Ruchi Majoo v. Sanjeev Majoo and Anand Kumar Mohatta v. State (Govt. of NCT of Delhi), affirming the principles that allow for quashing in appropriate circumstances.

In this case, the Court noted that the complainant had remarried and showed no interest in pursuing the case, which indicated that continuing the criminal proceedings would serve no purpose. Additionally, the allegations in the FIR were found to be vague and general in nature.

Conclusion:
The Supreme Court quashed the FIR, charge-sheet, and all related proceedings, bringing an end to the matrimonial dispute. The Court highlighted that in such circumstances, invoking powers under Article 142 was appropriate to prevent an abuse of the legal process.