In a relief to elderly parents-in-law, the Supreme Court has quashed criminal proceedings against them in a dowry harassment case, ruling that generalized accusations of “quarrelling” with the complainant do not meet the threshold for offences under Section 498A IPC or Sections 3 and 4 of the Dowry Prohibition Act, 1961. A bench of Justices Vikram Nath and Sandeep Mehta extended parity to the appellants—Dr. Sushil Kumar Purbey and his wife—mirroring the Patna High Court’s earlier dismissal of charges against the complainant’s sister-in-law from the same FIR.

The matrimonial discord erupted shortly after the complainant’s marriage to Dr. Rishi Raj on July 8, 2019. By March 31, 2021, the husband filed for divorce under Section 13 of the Hindu Marriage Act, 1955, citing irretrievable breakdown. Over a year later, on March 18, 2022, the wife lodged FIR No. 81/2022 at Lalit Narayan University Police Station, Darbhanga, alleging relentless cruelty and dowry demands—including a BMW car and luxury items—from her husband, in-laws, and sister-in-law, soon after the wedding. This triggered charges under IPC Sections 341 (wrongful restraint), 323 (voluntarily causing hurt), 498A (cruelty), and 34 (common intention), alongside Dowry Act provisions.

The Patna High Court, in its August 8, 2023, order in Criminal Miscellaneous No. 70355/2022, quashed proceedings solely against the sister-in-law, deeming the allegations omnibus and lacking specificity. It denied similar relief to the parents-in-law, finding a prima facie case based on the FIR’s narrative of persistent harassment. Aggrieved, the appellants approached the apex court, arguing identical vagueness: no distinct roles, dates, or acts attributed to them beyond routine family spats.

Authoring the verdict, Justice Nath scrutinized the FIR, noting:
“A comparative reading of the FIR reveals that the allegations levelled against the sister-in-law and those against the present appellants are, in all material particulars, identical. The FIR does not assign any specific or overt act to either appellant; there are no particular dates, places, or individual acts attributed to them. The lone allegation that stands separately against the present appellants is that they would quarrel. This, however, does not constitute a criminal offence and cannot, by itself, sustain cognizance of the offences…”

The bench lambasted the High Court’s inconsistent approach: “We are of the considered opinion that the High Court erred in applying different standards to persons who stand on an identical footing… Since the allegations against the present appellants and the sister-in-law are, in substance, the same, the reasoning that led the High Court to quash the proceedings against the sister-in-law ought equally to have led to the quashing of proceedings against the present appellants.”

Allowing the appeal, the Court set aside the impugned order’s denial of relief, quashing summons and proceedings against the parents-in-law. It clarified that observations are confined to quashing viability and do not prejudice the husband’s ongoing case, which shall proceed per law. This ruling reinforces safeguards against misuse of Section 498A, urging specificity in matrimonial cruelty pleas to prevent fishing expeditions.

Case Title: Dr. Sushil Kumar Purbey & Anr. versus The State of Bihar and Ors. | Criminal Appeal No. ………… of 2026 (Arising out of SLP(Crl.) No. 3075/2024) | 2026 INSC 212

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