MUPPIDI LAKSHMI NARAYANA REDDY & ORS. [APPELLANTS]  Vs.  THE STATE OF ANDHRA PRADESH & ANR.[RESPONDENTS]

CRIMINAL APPEAL (Arising out of SLP(Crl.) No(s). 2570 of 2018)

(2JB, AHSANUDDIN AMANULLAH and PRASHANT KUMAR MISHRA JJ., delivered by MISHRA, J.)

The appellants in this case challenged an order of the High Court which had dismissed their petition under Section 482 of the Criminal Procedure Code (CrPC), seeking to quash the criminal proceedings initiated in Criminal Case No. 359 of 2016. The case was pending before the Special Judicial Magistrate, First Class for Prohibition & Excise Cases in Guntur.

The appellants—A4, A5, and A6—are relatives of the husband (A1) of the de-facto complainant (respondent no. 2). A4 is the complainant’s sister-in-law, A5 is A4’s husband, and A6 is A4’s father-in-law. The complainant had married A1 on 24 May 2014, but left his company multiple times to live with her parents. Despite a temporary reconciliation through family mediation and withdrawal of legal complaints by both sides in April 2015, disputes continued. Eventually, the complainant left for the USA without informing her husband or in-laws, and A1 initiated divorce proceedings in June 2016. In retaliation, she lodged a fresh complaint implicating six people, including the three appellants.

The appellants contended that they had no role in the matrimonial discord between A1 and the complainant. They reside in Hyderabad and are engaged in their respective professions: A4 is a housewife, A5 a software engineer, and A6 a central government employee. They asserted that they had no involvement in the alleged dowry harassment. Notably, a separate case under Section 66C of the IT Act had also been registered against A1.

The High Court declined to quash the criminal proceedings, citing the existence of allegations against the appellants that required a trial. However, upon examining the matter, the Supreme Court noted that the allegations against the appellants were vague, omnibus, and lacked specific details, such as the dates of alleged visits to Guntur. The only accusation involved a general demand for dowry and taunting remarks, with no claims of physical abuse.

The Supreme Court referred to several precedents, including Geeta Mehrotra v. State of Uttar Pradesh and Dara Lakshmi Narayana v. State of Telangana, where the Court had cautioned against indiscriminately involving distant relatives of the husband in matrimonial disputes, particularly under Sections 498A IPC and 4 of the Dowry Prohibition Act. The Court emphasized the misuse of these provisions and the need to protect innocent family members from unnecessary harassment.

In Geeta Mehrotra, the Court had held that bald and general allegations were insufficient to justify prosecution of distant relatives. Similarly, in Dara Lakshmi Narayana, the Court observed that dragging in relatives who do not reside with the couple and against whom there are no specific allegations constitutes an abuse of the legal process.

In light of these principles, the Supreme Court held that the allegations against the appellants did not establish a prima facie case and continuing prosecution would amount to an abuse of the judicial process. Consequently, the appeal was allowed and the criminal proceedings in CC No. 359 of 2016 against the appellants were quashed.