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Synopsis

The Supreme Court has on April 23, 2025 quashed a dowry harassment complaint filed by a woman against the sister-in-law, her husband and her father-in-law after the complainant's husband sought dissolution of their 2014 marriage since she allegedly deserted him to live in the USA. 

A bench of Justices Ahsanuddin Amanullah and Prashant Kumar Mishra allowed a plea filed by Muppidi Lakshmi Narayana Reddy and others against the high court's order, which declined to quash the case against them, after noting that there were omnibus and general allegations against the appellants, a housewife, her software engineer husband and central government employee father-in-law.

The apex court noted as per the complaint, although the appellants resided at Hyderabad, they used to visit Guntur and during such visit they used to instigate the husband and his parents and would also join in demanding dowry. The initial allegation was of demand of Rs 5,00,000 made against the sister-in-law with a further statement that they used to taunt that if the husband would have married somewhere else, he would have got Rs 10 crores as dowry. 

"There is no allegation of any physical torture being perpetrated by the present appellants. The allegation is only of taunt and statement that they are highly placed having political influence and connection with Ministers as such they instigated husband and her in laws to pressurise the de-facto complainant to get additional dowry," the bench found.

The bench further recorded that there was no denial of the fact that the appellants resided at Hyderabad whereas the de-facto complainant stayed at Guntur in her marital house. There was no specific date as to when the present appellants visited Guntur and joined the main accused in demanding dowry from de-facto complainant.

Considering the growing trend of the dowry victim arraigning the relatives of the husband, this court in the matter of Geeta Mehrotra & Anr Vs State of Uttar Pradesh & Anr (2012) has deprecated the practice involving the relatives of the husband for the offence under Section 498A IPC and Section 4 of Dowry Prohibition Act, 1961, the bench pointed out.

In a recent judgment in the matter of Dara Lakshmi Narayana & Ors Vs State of Telangana & Anr (2024), this court has again reiterated and deprecated the practice of involving the relatives of the husband in dowry related matters, the bench highlighted.          

In the present case also, the court said, it was an admitted position that the appellants were residing at Hyderabad whereas the de-facto complainant stayed in her marital house at Guntur at the relevant point of time. She was presently staying in the USA. 

"There is omnibus allegation against the appellants that they too used to demand dowry or instigate the husband and in-laws who are not before us, in demanding dowry," the bench said.

Considering the entire facts of the case, the bench said, "We are of the view, having relied on this court’s previous decisions in Geeta Mehrotra and Dara Lakshmi Narayana, the present criminal case against the appellants deserves to be quashed".

The court allowed the appeal and quashed the criminal case against the appellants.    

As per facts of the matter, the marriage between de-facto complainant and Challa Poornananda Reddy was solemnised on May 24, 2014 at Guntur. After five months of the marriage, the de-facto complainant left the company of her husband and joined her parents to live at her parental house at Vidyanagar, Guntur. 

On persuasion, she joined her husband but again went back to her parental house and this act continued for some more time compelling the husband to send a legal notice followed by a petition for restitution of conjugal rights on February 18, 2015. During the pendency of this proceeding, she lodged a complaint before the concerned police on February 13, 2016. However, on intervention of elders, a compromise was arrived at on April 02, 2015 and the husband withdrew the case of restitution of conjugal rights and the de-facto complainant also withdrew her complaint before the concerned police.

She later left for the USA without intimating the husband or his family members and the dispute continued. The husband moved a petition for dissolution of marriage on June 21, 2016 and as a counterblast she again lodged an FIR against six accused persons, including the present appellants.

The appellants contended that they were nowhere connected with the dispute between the husband and the wife or the husband’s family members. They resided in Hyderabad. On the complaint of the father of the de-facto complainant, an offence under Section 66C of the Information Technology Act was registered against the husband, pending before the Special Judicial First-Class Magistrate for Prohibition and Excise, Guntur, Andhra Pradesh. The appellants said that accused no. 4 was a housewife, accused no. 5 was a Software Engineer in a Private Software Company and accused no. 6, was a Central Government employee and all were stationed at Hyderabad having no connection or intervention with the dispute between the de-facto complainant and her husband.      

However, the high court had refused to allow the quashing petition on the ground that there were allegations against the appellants for which a trial was required and those could not be disbelieved at the current stage.

Case Title: Muppidi Lakshmi Narayana Reddy & Ors Vs The State of Andhra Pradesh & Anr