New Delhi, September 24, 2025 – The Supreme Court of India has quashed criminal proceedings against Shobhit Kumar Mittal, who was accused of dowry harassment by his sister-in-law, holding that vague and general allegations without specific details cannot be the basis of prosecution.
The case arose from an FIR lodged on November 9, 2023, at Civil Lines Police Station, Meerut, by Jyoti Garg against her husband Mohit Mittal, mother-in-law Shashi Mittal, and her brother-in-law Shobhit Kumar Mittal. The FIR alleged harassment for dowry soon after her marriage in 2014, and claimed that persistent harassment led to a medical condition causing paralysis on her right side. The charges were filed under Sections 323 and 498A of the Indian Penal Code (IPC) and Sections 3 and 4 of the Dowry Prohibition Act.
Earlier this year, the Allahabad High Court refused to quash the FIR, observing that a prima facie case was made out. Mittal then appealed to the Supreme Court.
Supreme Court’s Observations
A Bench of Justices B.V. Nagarathna and R. Mahadevan noted that the FIR contained “vague and omnibus allegations” without specifying dates, instances, or details of the alleged harassment. The Court said that mere general accusations against family members could not justify criminal prosecution.
The judgment relied on earlier rulings, including the landmark State of Haryana vs. Bhajan Lal (1992) case, which laid down conditions under which courts can quash criminal proceedings to prevent abuse of law.
The Court also cited its recent decision in Dara Lakshmi Narayana vs. State of Bihar (2025), cautioning against the growing trend of indiscriminately naming all family members in matrimonial disputes without specific evidence.
“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,” the Bench observed.
The judges stressed that while Section 498A IPC was enacted to protect women from cruelty and dowry harassment, misuse of the provision through sweeping allegations could not be encouraged.
Outcome
The Supreme Court set aside the Allahabad High Court’s February 27, 2024 order and quashed FIR No. 347 of 2023 only in respect of Shobhit Kumar Mittal, the brother-in-law. Proceedings against the husband and mother-in-law remain unaffected.
The Court clarified that its observations would not prejudice any other pending legal proceedings between the parties.
Broader Significance
This judgment once again highlights the judiciary’s balancing act between protecting women from genuine cases of cruelty and preventing misuse of anti-dowry laws. It reinforces the principle that criminal law cannot be set in motion on the basis of unspecified or generalized accusations, and that courts must carefully scrutinize such complaints to prevent harassment of innocent family members.