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Prasanta Kumar Dhar & Another v. State of West Bengal & Another

Criminal Appeal · 2026 INSC 1087Decided 5 Oct 2026
Criminal Appeal arising out of SLP (Criminal) No. 16908 of 2024
Justice N. Kotiswar Singh · Justice N.V. Anjaria

Background

A woman complained of dowry demands, taunts and harassment by her husband and parents-in-law, including treatment during pregnancy and after the birth of a daughter. She also alleged that her husband and father-in-law forced her to sign a declaration acknowledging return of her jewellery and other personal property. Police filed a chargesheet against all three, and the parents-in-law sought to have the proceedings quashed. The Calcutta High Court removed only the charge of voluntarily causing hurt under Section 323 IPC and required the remaining accusations to proceed to trial, so the parents-in-law appealed.

Decision Breakdown

The Supreme Court allowed the appeal and quashed all proceedings arising from the FIR insofar as they concerned the two parents-in-law. Examining each remaining offence, it found that the allegations and investigation lacked sufficiently specific acts and supporting material connecting them to statutory cruelty or dowry demands. The record did not identify property entrusted to them and dishonestly misappropriated, or adequately substantiate the alleged criminal intimidation. The Court held that general accusations unsupported by the investigation could not justify putting these appellants through a criminal trial merely because they were relatives of the husband. It expressly confined its ruling to the parents-in-law and left the allegations against the husband and any civil remedies unaffected.

Lesson Learnt

Criminal proceedings against relatives in a matrimonial dispute require a factual basis connecting each person to the alleged offence. This judgment does not give relatives blanket immunity: specific allegations supported by material can justify prosecution, and relief for one accused does not automatically resolve the case against others.

Official source (sci.gov.in)View Judgment (PDF)

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