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Shobhit Kumar Mittal vs. State of Uttar Pradesh & Anr.

Not available · 2025 INSC 1152Decided 24 Sept 2025
Not available
Justice B.V. Nagarathna · Justice R. Mahadevan

Background

The complainant, married in 2014, left her matrimonial home after marital discord and both spouses initiated various proceedings against each other. In 2023, she filed an FIR against her husband, mother-in-law, and the appellant (her brother-in-law) alleging dowry harassment and hurt under Sections 323 and 498A IPC and the Dowry Prohibition Act, claiming a brain injury she suffered was linked to ongoing harassment. The Allahabad High Court declined to quash the FIR against the brother-in-law, finding a prima facie cognizable offence was disclosed.

Decision Breakdown

The Supreme Court quashed the FIR as against the appellant, finding the allegations against him were vague and omnibus, with no specific dates, incidents, or details of what he actually did, and no clear link between the alleged harassment and the medical injury described. Relying on its own precedent (Dara Lakshmi Narayana v. State of Bihar) and the classic Bhajan Lal guidelines, the Court reiterated that there is a well-recognized tendency to rope in the husband's entire family in matrimonial disputes with generalized accusations, and that such unsubstantiated, sweeping allegations cannot sustain a criminal prosecution against an extended family member.

Lesson Learnt

In matrimonial FIRs, merely naming an extended family member without specific, particularized allegations of their individual conduct is not enough to sustain criminal proceedings against them. Courts will quash such vague, omnibus complaints to prevent misuse of protective laws like Section 498A.

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

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