Abstract
The case arises from a matrimonial dispute between the de-facto complainant and her husband, leading to criminal proceedings against his relatives. Following marriage in 2014, the complainant repeatedly left her marital home and eventually relocated to the USA without informing her husband. Subsequent divorce proceedings initiated by the husband triggered a retaliatory FIR by the wife, accusing six persons, including the appellants who resided separately in Hyderabad. The allegations against them were general, with no specific instances of physical cruelty or particularized dowry demands cited. The Supreme Court, emphasizing caution against misuse of criminal law in matrimonial conflicts, noted the absence of concrete allegations and quashed the proceedings. Relying on precedents the Court reaffirmed the principle that vague accusations against non-residing relatives must not be entertained to avoid harassment and abuse of legal processes.
Details of case
| Case Name | MUPPIDI LAKSHMI NARAYANA REDDY & ORS. V. THE STATE OF ANDHRA PRADESH & ANR. |
| Citation | 2025 INSC 562 |
| Forum | Supreme Court of India |
| Number of Judges | 2 |
| Name of Judges | Justice Ahsanuddin Amanullah and Justice Prashant Kumar Mishra |
| Decided on | April 23, 2025 |
Historical background of case
The case was initially listed before trial court, specifically before Special Judicial Magistrate, Ist Class for Prohibition & Excise Cases, Guntur. The appellants then filed before the Hon’ble High Court of Andhra Pradesh a petition Procedure to have the proceedings quashed which were pending before the special judicial magistrate and the appeal was filled under section 482 of the 1973 Code of Criminal Procedure. However, the Hon’ble High court dismissed the petition on the ground that the case was that the trial was required for the allegations made against the appellants and in the Hon’ble High court’s view the allegations could not be disbelieved at the stage on which the trial was back then. The appellants reached Supreme Court of India through a special leave petition due to the dismissal order passed by High Court of Andhra Pradesh refusing to allow the petition.
Facts of the case
The marriage between the de-facto complainant (Respondent No. 2) and Challa Poornananda Reddy was solemnized on 24 May 2014 at Guntur, Andhra Pradesh. The de-facto complainant moved live with her parents in Vidyanagar, Guntur, after leaving her husband’s business after roughly five months of marriage. The pattern of separation and return persisted even after she was convinced to return to her husband’s house. leading the husband to issue a legal notice and file a petition for restitution of conjugal rights on 18 February 2015.
The de-facto complainant filed a police report against her spouse and his family on February 13, 2016, while the restitution petition was still pending. But because of to the elders’ involvement, a compromise was reached between the parties on April 2, 2015, and as a result, the husband retracted the petition for the restitution of conjugal rights, and the de-facto complainant withdrawn the police complaint. The disagreement continued after the settlement since the de-facto complainant went to the United States without telling her husband or his family..
This resulted into initiation of divorce proceedings by filing a petition for divorce on 21 June 2016 and these proceedings were initiated by the husband. As a counterblast to this, the de-facto complainant lodged another police complaint, which led to the registration of FIR No. 79 of 2016, implicating six persons including the present appellants. Separately, the de-facto complainant’s father filed a complaint under Section 66C of the Information Technology Act against the husband(A1), which was pending before the Special Judicial First-Class Magistrate for Prohibition and Excise Cases, Guntur.
The appellants no.1, and appellant no.2 who is husband of appellant no.1, and appellant no.3 who is father in law of appellant no.1, were not living with the couple and were all residents of Hyderabad and the couple resided at Guntur during the relevant period.
Allegations made by the de-facto complainant against the aforementioned appellants stated that they used to frequently visit Guntur and used to instigate accused no.1 (who is the husband of the de-facto complainant) to demand dowry and initially demanded rupees 5 lakh and also used to taunt the de-facto complainant that if her husband would have married somewhere else he would have easily got rupees 10 crores in dowry, while there were no allegations of physical torture these taunts were accompanied by other statements such as they had political influence and had connections with ministers and same was alleged to being done by the appellants for securing the additional dowry from de-facto complainant.