Arti Mehta & Ors. v. State of Madhya Pradesh & Anr., 2026

case arose out of a matrimonial dispute between the complainant-wife and her husband, who got married in November 2019.

In January 2023, the complainant lodged an FIR at Guna, Madhya Pradesh alleging offences under Section 498A IPC, Section 34 IPC, and Sections 3 & 4 of the Dowry Prohibition Act against her husband and his relatives.

The complainant alleged that substantial dowry in the form of cash, jewellery, and household articles had been given at the time of marriage.

She further alleged that after marriage she was subjected to harassment and unlawful demands for additional money.

Subsequently, proceedings under the Domestic Violence Act were also initiated against the husband and his relatives.

The complainant alleged:

• mental harassment,

• surveillance through hidden cameras,

• restrictions on movement, and

• threats involving a licensed firearm.

The Madhya Pradesh High Court refused to quash the FIR and Domestic Violence proceedings against the in-laws.

Aggrieved by the High Court order, the in-laws approached the Supreme Court seeking quashing of the criminal proceedings.

During pendency of the proceedings, the marriage between the complainant and her husband stood dissolved by a decree of divorce passed by the competent Family Court.

he Supreme Court allowed the appeals filed by the complainant’s in-laws.

The Court held that the allegations against the appellants were omnibus, generalized, and lacking in specific particulars.

The Bench observed that no direct or specific overt act constituting domestic violence, cruelty, harassment, or dowry demand was individually attributed to the appellants.

The Court emphasized that allegations merely stating that relatives:

• supported the husband,

• failed to intervene, or

• advised the complainant to adjust,
  were insufficient to attract criminal liability.

The Court held that prosecutions arising from matrimonial disputes require:

• specific allegations,

• distinct roles, and

• prima facie material indicating active involvement of each accused.

The Bench observed that criminal law cannot be used as an instrument to settle personal grievances or familial scores.

The Court stressed that courts must exercise heightened judicial scrutiny before allowing prosecution of relatives solely because of their relationship with the spouse.

The Supreme Court further observed that passive conduct or failure to intervene, though morally questionable, cannot automatically amount to criminal culpability.

The Court noted that continuation of proceedings under the Domestic Violence Act against the appellants would serve no useful purpose, especially after dissolution of marriage.

Accordingly, the Supreme Court quashed:

• the FIR,

• criminal proceedings, and

• Domestic Violence proceedings against the in-laws.

The judgment reinforces judicial safeguards against indiscriminate implication of relatives in matrimonial disputes.

The Supreme Court emphasized the need for specific factual foundations before extending criminal liability to family members.

The ruling seeks to prevent misuse of criminal law as a weapon in emotionally charged matrimonial conflicts.

By insisting upon individualized allegations and active participation, the Court strengthened procedural fairness in criminal prosecutions.

The judgment carefully balanced:

• protection of victims of domestic violence, and

• safeguarding innocent relatives from unnecessary criminal litigation.

The Court clarified that moral failure or passive conduct cannot automatically translate into criminal culpability.

The ruling contributes significantly to jurisprudence concerning:

• misuse of Section 498A IPC,

• Domestic Violence proceedings,

• dowry harassment allegations, and

• abuse of criminal process.

The decision also reiterates that courts must exercise heightened caution before prosecuting extended family members solely on the basis of relationship.