Legal Updates

Case Note: Sanjay D. Jain v. State of Maharashtra, Supreme Court of India, Criminal Appeal No. 12584 of 2024, decided on 26 September 2025

Headnote

The Supreme Court quashed criminal proceedings under Sections 498-A, 377, and 506 IPC against the in-laws of a complainant-wife, holding that vague and omnibus allegations without specific instances of cruelty or harassment cannot sustain prosecution. The Court clarified that proceedings would continue against the husband, who faced direct and specific allegations. This ruling reaffirms the principle that continuation of criminal proceedings in the absence of a prima facie case amounts to abuse of process.

Facts

• The complainant married Piyush Jain on 14 July 2021.
• She alleged harassment by her husband and his family through repeated dowry demands and claimed her husband subjected her to unnatural sexual acts.
• FIR No. 20/2022 was registered at Bajaj Nagar Police Station, Nagpur under Section 498-A IPC; later, Sections 377 and 506 IPC were added.
• The in-laws sought quashing of the FIR under Section 482 CrPC. The Bombay High Court (Nagpur Bench) rejected their plea.
• They appealed to the Supreme Court.

Issues

1. Whether vague and general allegations in an FIR can constitute a prima facie case under Section 498-A IPC against in-laws.
2. Whether proceedings under Sections 377 and 506 IPC could be sustained against relatives when allegations were directed solely at the husband.

Reasoning

• The Court emphasized that to constitute cruelty under Section 498-A IPC, allegations must show conduct that drives the victim to suicide, causes grave injury, or results in harassment for dowry.
• On examining the FIR, the Court found only one specific allegation against the mother-in-law (demand for clothes and jewellery), while the rest were vague and omnibus. Such allegations did not satisfy the legal threshold.
• The allegations of unnatural sex (Section 377 IPC) and intimidation (Section 506 IPC) were confined to the complainant’s husband. No case was made out against the in-laws.
• Relying on established precedents, the Court held that continuation of proceedings in such circumstances would amount to abuse of the process of law.

Decision

• FIR No. 20/2022 and the final report were quashed against the father-in-law, mother-in-law, and sister-in-law.
• Proceedings will continue against the husband under Sections 498-A, 377, and 506 IPC.
• Observations were restricted to the appellants (in-laws) and would not affect the merits of the case against the husband.

Endnotes / Case Law References

1. State of Haryana v. Bhajan Lal, 1990 INSC 363 — principles for quashing FIRs under Section 482 CrPC.
2. Digambar & Anr. v. State of Maharashtra & Anr., 2024 INSC 1019 — vague and omnibus allegations insufficient to constitute a prima facie case under Section 498-A IPC.
3. Sanjay D. Jain & Ors. v. State of Maharashtra & Ors., 2025 INSC 1168 (Supreme Court, 26 Sept 2025).

PDF of Sanjay D. Jain v. State of Maharashtra SANJAY D. JAIN VERSUS STATE OF MAHARASHTRA (SUPREME COURT)