Muppidi Lakshmi Narayana Reddy & Ors. v. The State of Andhra Pradesh & Anr. | 2025 INSC 562 | Supreme Court

Case Arising From: The case arose from a matrimonial dispute between the de-facto complainant and her husband, Challa Poornananda Reddy, following their marriage on 24.05.2014 in Guntur. The complainant’s repeated departures to her parental home led to a petition for restitution of conjugal rights by the husband on 18.02.2015 and a police complaint by the complainant on 13.02.2016.

A compromise on 02.04.2015 resulted in withdrawals, but the dispute persisted. The husband’s divorce petition on 21.06.2016 prompted the complainant to file FIR No. 79 of 2016, alleging dowry demands and harassment, leading to C.C. No. 359 of 2016 before the Special Judicial Magistrate, Ist Class for Prohibition & Excise Cases, Guntur.

A separate complaint under Section 66C of the Information Technology Act by the complainant’s father resulted in C.C. No. 775 of 2016. The appellants’ Section 482 Cr.P.C. petition to quash C.C. No. 359 of 2016 was dismissed by the High Court, leading to the present appeal.

1. Name of the Case: Muppidi Lakshmi Narayana Reddy & Ors. v. The State of Andhra Pradesh & Anr.

2. Tag: Judgment

3. SCR Citation: Not mentioned in the document.

4. Neutral Citation: 2025 INSC 562

5. Judgment Authored by: Hon’ble Justice Prashant Kumar Mishra*

6. Date of Judgment: April 23, 2025

7. Petitioner Name(s):

• Muppidi Lakshmi Narayana Reddy (A4)
• Appellant No. 2 (A5, husband of A4, name not specified)
• Appellant No. 3 (A6, father-in-law of A4, name not specified)

8. Respondent Name(s):

• The State of Andhra Pradesh
• De-facto complainant (name not specified)

9. Accused:

• Accused No. 1 (A1): Challa Poornananda Reddy (Husband)
• Accused Nos. 2 and 3: Not specified in the document (Husband’s parents)
• Accused No. 4 (A4): Muppidi Lakshmi Narayana Reddy (Sister-in-law of complainant)
• Accused No. 5 (A5): Husband of A4
• Accused No. 6 (A6): Father-in-law of A4

10. Victim: De-facto complainant (name not specified, wife of Challa Poornananda Reddy)

11. Date the Case was Started on: Not mentioned in the document.

12. Date the Case was Ended on: April 23, 2025

13. Case Number:

• CRIMINAL APPEAL NO(s). OF 2025 (Arising out of SLP(Crl.) No(s). 2570 of 2018)
• C.C. No. 359 of 2016
• FIR No. 79 of 2016
• C.C. No. 775 of 2016

14. Disposal Nature: Appeal Allowed

15. Case Type: SPECIAL LEAVE PETITION (CRIMINAL)

16. Law Type:

• Criminal Law
• Matrimonial Law
• Information Technology Law

17. Final Decision: The appeal is allowed, and Criminal Case No. 359 of 2016 against the appellants is quashed.

18. Facts: The marriage between the de-facto complainant (respondent no. 2) and Challa Poornananda Reddy (A1) was solemnized on 24.05.2014 at Guntur. Five months later, the complainant left her husband’s home to live with her parents in Vidyanagar, Guntur. Despite attempts at reconciliation, she repeatedly returned to her parental home, prompting her husband to issue a legal notice and file a petition for restitution of conjugal rights on 18.02.2015.

During these proceedings, the complainant lodged a police complaint on 13.02.2016, but a compromise was reached on 02.04.2015, leading to the withdrawal of both the restitution petition and the complaint. The complainant later moved to the USA without informing her husband or his family, and the dispute persisted. On 21.06.2016, the husband filed for dissolution of marriage. In response, the complainant lodged FIR No. 79 of 2016, alleging dowry demands and harassment against six accused, including the appellants (A4: sister-in-law, A5: her husband, A6: her father-in-law), who reside in Hyderabad.

A separate complaint by the complainant’s father led to charges under Section 66C of the Information Technology Act against the husband, pending as C.C. No. 775 of 2016. The appellants, residing in Hyderabad, claimed no involvement in the matrimonial dispute. The High Court dismissed their Section 482 Cr.P.C. petition to quash C.C. No. 359 of 2016, citing allegations requiring trial. The Supreme Court reviewed these proceedings, focusing on the appellants’ lack of direct involvement.

19. Issues Framed:

1. Whether the allegations against the appellants in C.C. No. 359 of 2016 are specific and sufficient to warrant criminal prosecution under Section 498A IPC and Section 4 of the Dowry Prohibition Act?
2. Whether the continuation of criminal proceedings against the appellants constitutes an abuse of the legal process, given their residence in Hyderabad and lack of direct involvement in the matrimonial dispute?
3. Whether the High Court erred in dismissing the appellants’ petition under Section 482 Cr.P.C. to quash the proceedings?

20. Ratio Decidendi (Reasonings):

• The allegations against the appellants are omnibus and general, lacking specific details about their visits to Guntur or direct involvement in dowry demands, and thus do not justify criminal prosecution (Page 4, Para 8; Page 8, Para 11).
• The appellants reside in Hyderabad, while the complainant lived in Guntur, and there are no specific dates or instances of their alleged dowry demands or instigation, rendering the allegations vague (Page 8, Para 11).
• Relying on precedents like Geeta Mehrotra & Anr. v. State of Uttar Pradesh & Anr. and Dara Lakshmi Narayana & Ors. v. State of Telangana & Anr., the practice of implicating relatives of the husband in dowry cases without specific evidence is deprecated, and such prosecutions constitute an abuse of process (Page 5, Para 9; Page 6, Para 10).
• The High Court erred in not exercising its powers under Section 482 Cr.P.C. to prevent misuse of legal processes, as the allegations lack a clear prima facie case against the appellants (Page 8, Para 10).

21. Evidence & Findings:

• Evidence Type: Document (FIR No. 79 of 2016)
  • Description: Complaint alleging dowry demands and instigation by the appellants and others.
  • Findings: Contains omnibus and general allegations without specific dates or instances of the appellants’ involvement in demanding dowry or instigating A1 to A3 (Page 4, Para 8).
• Evidence Type: Document (Chargesheet in C.C. No. 359 of 2016)
  • Description: Chargesheet filed against the appellants and others for offences under Section 498A IPC and Section 4 of the Dowry Prohibition Act.
  • Findings: Lacks legal basis for cognizance against the appellants due to vague allegations, similar to findings in Geeta Mehrotra (Page 5, Para 9).
• Evidence Type: Statement (Complainant’s Allegations)
  • Description: Allegations that the appellants, during visits to Guntur, instigated A1 to A3 and taunted the complainant about dowry, claiming A4 demanded Rs. 5,00,000 and that A1 could have received Rs. 10 crores elsewhere.
  • Findings: No specific evidence of physical torture or precise instances of dowry demands by the appellants, and their residence in Hyderabad undermines their active involvement (Page 4, Para 8; Page 8, Para 11).

22. Exhibit:

• Exhibits: None mentioned in the document.

23. Headnote: Generated by Karma AI Team
Criminal Appeal – Section 498A IPC – Section 4 of Dowry Prohibition Act, 1961 – Section 482 Cr.P.C. – Quashing of criminal proceedings – Omnibus allegations against husband’s relatives – Appellants residing in different city – No specific evidence of involvement – Continuation of proceedings abuse of process – Appeal allowed, proceedings quashed.

24. Prayer: Not mentioned in the document.

25. Case Referred:

• Petitioner/Appellant Cited Cases:
  • Case Name: Geeta Mehrotra & Anr. v. State of Uttar Pradesh & Anr.
    • Citation: (2012) 10 SCC 741
    • Relevance: Deprecated the practice of implicating husband’s relatives in dowry cases without specific allegations, quashing proceedings against a sister-in-law not residing with the complainant (Page 5, Para 9).
    • Judicial Consideration: Relied upon to argue that vague allegations against the appellants do not justify prosecution.
    • Exact Quote: “Their Lordships of the Supreme Court in Ramesh case [(2005) 3 SCC 507 : 2005 SCC (Cri) 735] had been pleased to hold that the bald allegations made against the sister-in-law by the complainant appeared to suggest the anxiety of the informant to rope in as many of the husband’s relatives as possible…” (Page 5, Para 9).
  • Case Name: Dara Lakshmi Narayana & Ors. v. State of Telangana & Anr.
    • Citation: (2024) INSC 953: (2024) 12 SCR 559
    • Relevance: Reiterated that relatives living in different cities with no specific allegations of involvement should not be prosecuted, as it constitutes abuse of process (Page 6, Para 10).
    • Judicial Consideration: Supported quashing the proceedings due to lack of specific allegations against the appellants.
    • Exact Quote: “A mere reference to the names of family members in a criminal case arising out of a matrimonial dispute, without specific allegations indicating their active involvement should be nipped in the bud…” (Page 6, Para 10).
  • Case Name: G.V. Rao v. L.H.V. Prasad
    • Citation: (2000) 3 SCC 693
    • Relevance: Highlighted the rise in matrimonial disputes and the misuse of legal provisions to implicate family members, discouraging unnecessary litigation (Page 7, Para 30).
    • Judicial Consideration: Used to emphasize the need to avoid prosecuting relatives without clear evidence.
    • Exact Quote: “There has been an outburst of matrimonial disputes in recent times… those who could have counselled and brought about rapprochement are rendered helpless on their being arrayed as accused in the criminal case…” (Page 7, Para 30).
  • Case Name: Preeti Gupta v. State of Jharkhand
    • Citation: (2010) 7 SCC 667
    • Relevance: Advised courts to scrutinize allegations against relatives living in different cities with caution to prevent misuse of Section 498A IPC (Page 8, Para 31).
    • Judicial Consideration: Supported the need for careful examination of vague allegations against the appellants.
    • Exact Quote: Not quoted verbatim in the document.
• Respondent Cited Cases:
  • None mentioned in the document.

26. Complete Timeline:

• 24.05.2014: Marriage between the de-facto complainant and Challa Poornananda Reddy (A1) solemnized in Guntur (Page 2, Para 4).
• October 2014: Complainant left her husband’s home to live with her parents in Vidyanagar, Guntur (Page 2, Para 4).
• 18.02.2015: Husband filed a petition for restitution of conjugal rights (Page 2, Para 4).
• 13.02.2016: Complainant lodged a police complaint (Page 2, Para 4).
• 02.04.2015: Compromise reached, leading to withdrawal of the restitution petition and the complainant’s complaint (Page 2, Para 4).
• 2016: Complainant moved to the USA without informing her husband or his family (Page 3, Para 5).
• 21.06.2016: Husband filed a petition for dissolution of marriage (Page 3, Para 5).
• 2016: Complainant lodged FIR No. 79 of 2016 against six accused, including the appellants, for dowry demands and harassment (Page 3, Para 5).
• 2016: Chargesheet filed, leading to C.C. No. 359 of 2016 before the Special Judicial Magistrate, Ist Class for Prohibition & Excise Cases, Guntur (Page 1, Para 2).
• 2016: Complainant’s father filed a complaint under Section 66C of the Information Technology Act, pending as C.C. No. 775 of 2016 (Page 3, Para 6).
• 23.04.2025: Supreme Court allowed the appeal and quashed C.C. No. 359 of 2016 against the appellants (Page 9, Para 12).

27. Acts/Rules/Orders Referred:

• Name: Code of Criminal Procedure, 1973
  • Type: Act
  • Section: Section 482
  • Quoted Text: Not quoted verbatim in the document.
  • Context: Invoked by the appellants to seek quashing of C.C. No. 359 of 2016, dismissed by the High Court but allowed by the Supreme Court (Page 1, Para 2; Page 9, Para 12).
• Name: Indian Penal Code, 1860
  • Type: Act
  • Section: Section 498A
  • Quoted Text: Not quoted verbatim in the document.
  • Context: Alleged against the appellants for cruelty related to dowry demands, but found to be based on vague allegations (Page 5, Para 9; Page 6, Para 10).
• Name: Dowry Prohibition Act, 1961
  • Type: Act
  • Section: Section 4
  • Quoted Text: Not quoted verbatim in the document.
  • Context: Alleged against the appellants for demanding dowry, but lacked specific evidence (Page 5, Para 9).
• Name: Information Technology Act, 2000
  • Type: Act
  • Section: Section 66C
  • Quoted Text: Not quoted verbatim in the document.
  • Context: Invoked in a separate complaint by the complainant’s father against the husband (A1), pending as C.C. No. 775 of 2016 (Page 3, Para 6).

28. Acts/Rules/Orders under which the Case Falls:

• Indian Penal Code, 1860 (Section 498A)
• Dowry Prohibition Act, 1961 (Section 4)
• Code of Criminal Procedure, 1973 (Section 482)

29. Literature Citation:

• None mentioned in the document.

30. Appearances for Parties:

• For Petitioner/Appellant: Not specified (referred to as “learned counsel for the parties”) (Page 4, Para 8).
• For Respondent: Not specified (referred to as “learned counsel for the parties”) (Page 4, Para 8).

31. Petitioner(s)/Appellant(s) Arguments:

• Argument 1: The appellants (A4: housewife, A5: software engineer, A6: Central Government employee) reside in Hyderabad and have no connection to the matrimonial dispute between the complainant and her husband in Guntur (Page 3, Para 6).
  • Summary: Their residence and lack of involvement preclude their liability.
• Argument 2: The allegations are omnibus and lack specific details, such as dates of visits to Guntur or direct acts of dowry demands, and are an attempt to rope in the husband’s relatives, as deprecated in Geeta Mehrotra and Dara Lakshmi Narayana (Page 4, Para 8; Page 5, Para 9; Page 6, Para 10).
  • Summary: Vague allegations do not justify prosecution.
• Argument 3: The complainant’s FIR was filed as a counterblast to the husband’s divorce petition, indicating ulterior motives to harass the appellants (Page 3, Para 5; Page 8, Para 10).
  • Summary: The FIR is a misuse of legal provisions for personal vendetta.

32. Respondent(s)/Defendant(s) Arguments:

• Argument 1: The appellants visited Guntur and instigated A1 to A3 to demand dowry, including a specific demand of Rs. 5,00,000 by A4, and taunted that A1 could have received Rs. 10 crores elsewhere (Page 4, Para 8).
  • Summary: The appellants actively participated in dowry-related harassment.
• Argument 2: The allegations in the FIR and chargesheet require a trial to ascertain their veracity, and cannot be disbelieved at the quashing stage (Page 4, Para 7).
  • Summary: A prima facie case exists, necessitating judicial scrutiny.

33. Judges (Assent/Dissent):

• Hon’ble Justice Prashant Kumar Mishra (Authored, Assented)
• Hon’ble Justice Ahsanuddin Amanullah (Assented) No dissenting opinions recorded.

34. Legal Jargons and Maxims:

• Omnibus Allegations: General and non-specific accusations lacking detailed evidence (Page 4, Para 8). Used to describe the vague claims against the appellants.
• Abuse of Process of Law: Misuse of legal proceedings for improper purposes (Page 6, Para 10). Applied to the prosecution of the appellants based on insufficient evidence.

35. Case Arising From: The case arose from a matrimonial dispute between the de-facto complainant and her husband, Challa Poornananda Reddy, following their marriage on 24.05.2014 in Guntur. The complainant’s repeated departures to her parental home led to a petition for restitution of conjugal rights by the husband on 18.02.2015 and a police complaint by the complainant on 13.02.2016.

A compromise on 02.04.2015 resulted in withdrawals, but the dispute persisted. The husband’s divorce petition on 21.06.2016 prompted the complainant to file FIR No. 79 of 2016, alleging dowry demands and harassment, leading to C.C. No. 359 of 2016 before the Special Judicial Magistrate, Ist Class for Prohibition & Excise Cases, Guntur.

A separate complaint under Section 66C of the Information Technology Act by the complainant’s father resulted in C.C. No. 775 of 2016. The appellants’ Section 482 Cr.P.C. petition to quash C.C. No. 359 of 2016 was dismissed by the High Court, leading to the present appeal.