Background:

In the present case, the petitioner, a married woman, sought criminal action against her husband and ten of his relatives under Section 156(3) CrPC (Section 175(3) BNSS), alleging domestic violence, criminal intimidation, cruelty under Section 498A IPC (Section 85 BNS), and dowry-related offences under Sections 3 and 4 of the Dowry Prohibition Act. However, due to inconsistencies between her complaint and statements recorded under Sections 200 and 202 CrPC (Section 223 & 225 BNSS respectively), the Magistrate issued summons only to the husband and his parents.

Subsequently, the husband and his parents approached the Allahabad High Court under Section 482 CrPC (Section 528 BNSS), which quashed the entire prosecution, citing the vagueness of the allegations, lack of medical evidence, and misuse of process in naming extended family members without substantiation.

Issues

• Did the inconsistencies in Disha’s sworn statements and her failure to produce any medical evidence for serious allegations like a fractured hand- render her claims legally unsustainable and undermine the credibility of the complaint?

• Was the Allahabad High Court justified in invoking its inherent jurisdiction under Section 482 CrPC (Section 528 BNSS), to quash proceedings particularly noting the inclusion of extended family and the seeming contradiction of seeking conjugal rights despite alleging cruelty as an abuse of the criminal justice system?

Observation:

The Supreme Court observed that:

• • The Court found that Disha “took contrary stands” between her written complaint and her submissions under Sections 200/202 CrPC (Section 223 & 225 BNSS respectively), notably omitting serious allegations like being expelled and abused.
• • The Court flagged the puzzling fact that, even while alleging cruelty and dowry demand, Disha later filed for restitution of conjugal rights- a move described as “paradoxical,” which cast suspicion on her motives.
• • Citing precedents like Geeta Mehrotra and Preeti Gupta, the Court condemned the broad-brush naming of ten family members without credible or individualized allegations- a misuse of anti-dowry statutes.
• • It was observed that the Allahabad High Court rightly quashed the proceedings under Section 482 CrPC (Section 528 BNSS), to prevent abuse of process and defend innocent family members, stating there was “absolutely no reason to interfere”.

Decision:

The Supreme Court laid down the decision as mentioned below:

• • The Supreme Court dismissed Disha Kapoor’s Special Leave Petition, thereby upholding the Allahabad High Court’s quashing of the criminal proceedings initiated under Sections 498A, 325, 506 IPC (Section 85, 117(2), 351(2) & (3) BNS respectively), and Sections 3 & 4 Dowry Prohibition Act.
• • It found no merit in overturning the quashing order, affirming that the High Court rightly exercised its inherent powers under Section 482 CrPC (Section 528 BNSS), to terminate proceedings that were found to be abusive and lacking prima facie substance.

Why this case matters?

• The judgment underscores that while provisions like Section 498A IPC (Section 85 BNS) and the Dowry Prohibition Act are essential for protecting women, their misuse to harass in-laws or settle personal scores without credible evidence undermines the integrity of the legal process.

• The Supreme Court affirmed the High Court’s use of its inherent powers to quash proceedings that are prima facie frivolous or vexatious especially when allegations against extended family are vague, inconsistent, or unsupported.

• The case highlights the need for clear, fact-based allegations supported by medical or documentary evidence and consistent statements. It sends a strong message that criminal law cannot be misused to settle personal or marital disputes.

Laws related therewith:

Under BNS:

• • Section 85: Cruelty by husband or in-laws
• • Section 117(2): Voluntarily causing grievous hurt
• • Section 351 (2) & (3): Criminal intimidation

Under BNSS:

• • Sections 223 & 225: Magistrate’s examination and inquiry before summoning
• • Section 175(3): Power to order investigation upon complaint
• • Section 528: Inherent power of High Courts to quash criminal proceedings (as guided by Bhajan Lal framework) 

Under Hindu Marriage Act, 1955:

• • Section 9 & 13: Restitution of conjugal rights and grounds for divorce.

Under Dowry Prohibition Act, 1961:

• • Sections 3 & 4: Prohibiting giving/taking dowry.

Judicial Precedents:

• State of Haryana v. Bhajan Lal (1992): Both Allahabad and the Supreme Court applied these principles to conclude that Disha’s complaint was vague, unsupported by evidence, and likely motivated by misuse of the process.

• Preeti Gupta & Another v. State of Jharkhand (2010) & Geeta Mehrotra v. State of U.P. (2012): The Court cited these precedents to underscore the impropriety of including ten in-laws without substantiated acts against them.

• Arnesh Kumar v. State of Bihar (2014): Constrain automatic arrests in dowry-related offences under Section 41(1)(A), CrPC (Section 35 BNSS), to prevent pre-emptive detentions.