The Supreme Court has quashed criminal proceedings against an NRI husband accused of dowry death, cruelty and harassment following the suicide of his wife in Toronto, Canada, holding that the allegations were vague and unsupported by sufficient material.
A Bench of Justice B.V. Nagarathna and Justice Manmohan allowed the appeal filed by Piyush, setting aside the Bombay High Court’s order refusing to quash the FIR registered against him in Maharashtra.
Background
The appellant married the deceased on January 3, 2021. The couple initially lived with his family in Chandrapur before moving to Toronto, Canada, in February 2022.
On June 11, 2023, the wife died after jumping from the 22nd floor of their residential apartment. A handwritten suicide note recovered from the apartment stated that she was struggling to find employment and felt “stupid and useless.”
Her father subsequently lodged an FIR alleging dowry demands, physical and mental cruelty, and harassment by the husband and his family. The FIR invoked Sections 304B, 323, 498A and 504 read with Section 34 of the Indian Penal Code, along with Sections 3 and 4 of the Dowry Prohibition Act.
Canadian Investigation Found No Foul Play
The Canadian coroner’s report attributed the death to multiple blunt impact trauma caused by the fall. The Toronto Police investigation found that the handwriting in the suicide note matched the deceased’s handwriting and that there were no signs of struggle or foul play in the apartment.
The police also examined CCTV footage, which showed that the husband was not at home at the time of the incident. The investigation was subsequently closed.
Supreme Court’s Findings
The Court observed that the allegations of dowry demands related to 2021 and 2022, but no complaint had been made during the marriage before the wife’s death.
It noted that the suicide note did not refer to the husband or his family and attributed the deceased’s distress to her employment difficulties and studies.
The Bench further observed that the alleged exchange of gold jewellery and money, when considered in the context of the material on record, did not establish that the transactions were made pursuant to unlawful dowry demands.
The Court held that the prosecution had failed to establish a reasonable nexus between the alleged dowry demands, cruelty and the wife’s death.
General Allegations Insufficient to Sustain Prosecution
The Supreme Court reiterated that allegations of cruelty and harassment must be supported by specific facts and material. Mere general allegations, without particulars of the alleged offending acts, cannot justify continuing criminal proceedings.
Applying the principles laid down in State of Haryana v. Bhajan Lal, the Court held that the case fell within the categories warranting exercise of the High Court’s inherent powers to prevent abuse of process.
The Bench also emphasised that courts must scrutinise matrimonial complaints carefully and adopt a pragmatic approach to prevent miscarriage of justice.
FIR and Proceedings Quashed
The Supreme Court set aside the Bombay High Court’s order dated January 8, 2025, and quashed FIR No. 212/2023 registered at Satara Police Station, along with all consequential proceedings.
The appeal was accordingly allowed.
Case Details
Representation:-
For the Petitioner(s): Mr. Bhagat Chugh, Advocate, Mr. Jai Allagh, Advocate, Mr. Siddharth Jain, Advocate, Mr. Ekam Bath, Advocate, Mr. Siddharth Jain, Advocate-on-Record.
For the Respondent(s): Mr. Varad Kilor, Advocate, Mr. Siddharth Dharmadhikari, Advocate, Mr. Aaditya Aniruddha Pande, Advocate-on-Record, Mr. Shrirang B. Varma, Advocate, Mr. Sachin Pahwa, Advocate, Dr. Arvind S. Avhad, Advocate-on-Record, Mr. Rishabh Singh, Advocate, Mrs. Param Preet Kaur, Advocate.
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