Case Note

Shobhit Kumar Mittal v. State of Uttar Pradesh & Anr.
Supreme Court of India, Criminal Appeal (arising out of SLP (Crl.) No. 4069 of 2024), decided on September 24, 2025
Coram: B.V. Nagarathna, J. and R. Mahadevan, J.

Headnote

Criminal Law — Quashing of FIR — Sections 323, 498A IPC and Sections 3 & 4, Dowry Prohibition Act, 1961 — Allegations of cruelty and dowry harassment against husband’s brother (brother-in-law) — FIR containing vague and omnibus allegations without specific instances of cruelty or demand of dowry — No proximate act attributed to the appellant — Principles in State of Haryana v. Bhajan Lal reiterated — Held, continuation of proceedings would amount to abuse of process — FIR quashed qua the appellant.

Facts

The complainant (Respondent No. 2) married Mohit Mittal, brother of the appellant, in May 2014. Alleging persistent dowry harassment and cruelty by her husband, mother-in-law, and brother-in-law (the appellant), she filed an FIR on November 9, 2023 at PS Civil Lines, Meerut under Sections 323, 498A IPC and Sections 3 and 4 of the Dowry Prohibition Act. The Allahabad High Court dismissed a writ petition seeking quashing of the FIR, observing that a prima facie cognizable offence was disclosed.

The appellant approached the Supreme Court, contending that the allegations against him were vague, lacking specific dates, instances, or particulars of harassment.

Issue

Whether criminal proceedings under Sections 323, 498A IPC and Sections 3 & 4 of the Dowry Prohibition Act can be sustained against the brother-in-law where the FIR contains only vague, omnibus allegations without specific details of cruelty or demand of dowry.

Decision

Allowing the appeal, the Supreme Court quashed the FIR against the appellant.

Ratio Decidendi

1. Vague and omnibus allegations insufficient: Mere general assertions of harassment or cruelty, without specific incidents, particulars, or role attribution, cannot attract liability under Sections 323 or 498A IPC.

2. Application of Bhajan Lal principles: When allegations in an FIR do not prima facie disclose any offence or are inherently improbable, courts must exercise their power under Article 226 of the Constitution or Section 482 CrPC to quash proceedings to prevent abuse of law.

3. Caution against indiscriminate arraignment of family members: Courts must remain vigilant to the growing tendency of naming all relatives of the husband in matrimonial disputes without cogent material, as reiterated in Dara Lakshmi Narayana v. State of Bihar.

Held

The FIR No. 347/2023 dated 09.11.2023 is quashed qua the appellant (brother-in-law). Proceedings against the husband and mother-in-law remain unaffected.

Endnotes

1. State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335.

2. Dara Lakshmi Narayana v. State of Bihar, (2025) 3 SCC 735.

Download PDF of judgement in Shobhit Kumar Mittal v. State of Uttar Pradesh & Anr Shobhit Kumar Mittal vs State of UP (Supreme Court)