Supreme Court delivers key ruling on misuse of Section 498A IPC in dowry harassment cases.
SC QUASHES VAGUE 498A DOWRY FIR AGAINST BROTHER-IN-LAW
CASE SUMMARY – The Supreme Court in Shobhit Kumar Mittal vs. State of Uttar Pradesh quashed FIR No.347/2023 accusing the appellant of dowry harassment and cruelty under IPC Sections 323, 498A and Dowry Act Section 3,4. The Court found the wife’s allegations vague and lacking specific instances of cruelty or injury. Relying on State of Haryana v. Bhajan Lal, it held that generalized accusations cannot sustain criminal prosecution and warned against misuse of Section 498A to settle matrimonial disputes. The High Court’s refusal to quash was set aside, and proceedings against the appellant were terminated while leaving other matrimonial disputes unaffected.
| ASPECTS | DETAILS |
| Case Title | Shobhit Kumar Mittal vs. State of Uttar Pradesh & Another |
| Introduction | Supreme Court of India Criminal Appeal arising from SLP (Crl) No.4069 of 2024 challenging the Allahabad High Court’s refusal to quash FIR No.347/2023. |
| Factual Background | FIR filed by Jyoti Garg against her husband, mother-in-law, and brother-in-law (appellant) alleging dowry harassment and cruelty under and Dowry Prohibition Act. Allegations included mental harassment and an incident of paralysis. |
| Legal Issues | Whether vague and omnibus allegations in an FIR under Sections 323, 498A IPC and Sections 3,4 Dowry Act warrant quashing under Article 226 of the Constitution and Section 482 CrPC. |
| Applicable Law |
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| Analysis | FIR lacked specific incidents, dates, or details linking appellant to cruelty or hurt. Supreme Court applied Bhajan Lal tests, stressing caution against misuse of Section 498A and importance of concrete allegations. |
| Conclusion | High Court’s refusal to quash was set aside. FIR No.347/2023 and related proceedings were quashed against the appellant. Other pending disputes to continue on their merits. |
| Current Scenario | As of 24 September 2025, the Supreme Court judgment stands; the FIR is quashed regarding the appellant, reinforcing scrutiny of vague 498A/dowry allegations. |
“Mere sweeping allegations of dowry harassment without concrete details cannot justify criminal prosecution.”
SOURCE – SUPREME COURT OF INDIA
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