Summary and Analysis of Mange Ram Vs. State Of Madhya Pradesh & Another

1. Heading of the Judgment

MANGE RAM vs. STATE OF MADHYA PRADESH & ANOTHER
(Supreme Court of India, Criminal Appeal arising from SLP (Crl.) No. 10817 of 2024; Decided on August 12, 2025)

Citation: MANGE RAM vs. STATE OF MADHYA PRADESH & ANR., 2025 INSC 962 (Supreme Court of India).

2. Relevant Laws and Sections

The judgment interprets:

• Section 498A of Indian Penal Code (IPC):
  Criminalizes cruelty by husband or his relatives against a wife (punishable up to 3 years + fine).
  "Cruelty" includes:
  (a) Conduct likely to drive woman to suicide/cause grave injury.
  (b) Harassment to coerce unlawful dowry demands.

• Sections 3 & 4 of Dowry Prohibition Act, 1961:
  Section 3: Penalty for giving/taking dowry (min. 5 years imprisonment + fine).
  Section 4: Penalty for demanding dowry (min. 6 months, max. 2 years + fine).

• Section 482 of CrPC:
  Empowers High Courts to quash proceedings to prevent abuse of process/secure justice.

• Article 142 of Constitution:
  Grants Supreme Court power to pass orders for "complete justice."

3. Basic Judgment Details

• Parties:
  Appellant: Mange Ram (Father-in-law of complainant).
  Respondents:
  State of Madhya Pradesh (Prosecution).
  Respondent No. 2 (Complainant/Wife of appellant’s son; did not appear in Supreme Court).

• Key Events:
  2017: Marriage between appellant’s son and Respondent No. 2.
  2019: Marital discord; Respondent No. 2 left matrimonial home (May 2019).
  21.07.2019: FIR lodged against appellant, his son, mother-in-law, and sister-in-law for dowry harassment and assault.
  24.08.2021: Divorce decree granted between appellant’s son and Respondent No. 2.
  07.05.2024: High Court quashed proceedings against mother-in-law/sister-in-law but upheld against appellant and his son.

• Core Issue:
  Whether criminal proceedings against appellant (father-in-law) should be quashed.

4. Explanation of the Judgment

A. Defects in Prosecution Case

• Belated FIR:
  Alleged incident (slapping + dowry demand) occurred on 02.06.2019 at Jabalpur Railway Station.
  FIR filed 49 days later (21.07.2019) with no explanation for delay.

• Inconsistency with Counselling Records:
  Parties attended police counselling on 26.05.2019 and 02.06.2019.
  No mention of dowry demands or assault during counselling; instead, parties agreed to remarry.

• Motivated Timing:
  FIR filed after appellant’s son initiated divorce proceedings (20.06.2019), suggesting counterblast.

B. Legal Principles Applied

1. Misuse of Dowry Laws:
   Citing Dara Lakshmi Narayana vs. State of Telangana (2025) 3 SCC 735:
   Relatives should not be roped into matrimonial cases without specific allegations.
   Criminal law cannot be used as a tool for harassment.

2. Impact of Divorce:
   Citing Mala Kar (2024) and Arun Jain (2024):
   Continuation of criminal proceedings after divorce serves "no useful purpose" and perpetuates bitterness.

3. Quashing Power under Article 142:
   Citing Gian Singh vs. State of Punjab (2012) 10 SCC 303 and Naushey Ali vs. State of U.P. (2025) 4 SCC 78:
   Proceedings may be quashed to secure "complete justice" where:
   Parties have moved on post-divorce.
   Allegations lack specificity or are belated.
   Trial would be "futile" and "abuse of process."

C. Supreme Court’s Reasoning

• No Specific Role of Appellant:
  Allegations against appellant were generic ("demanded ₹5 lakhs" and "slapped once").
  High Court already quashed proceedings against mother-in-law/sister-in-law for identical defects.

• Marital Bond Dissolved:
  Divorce decree (24.08.2021) attained finality; parties leading separate lives.
  Continuing proceedings against father-in-law would "only prolong bitterness."

• Lack of Proximate Cause:
  No evidence appellant resided with the couple or actively participated in alleged harassment.

D. Final Ruling

• Proceedings Quashed:
  Invoking Article 142, the Supreme Court:
  Set aside High Court’s order dated 07.05.2024.
  Quashed FIR No. 58/2019 (Mahila PS, Jabalpur) and chargesheet dated 18.08.2019 against appellant.

• Key Observation:
  "Once marital ties end, continuation of criminal proceedings against family members – especially with stale, vague allegations – burdens the justice system and entrenches hostility. The law must prevent misuse while protecting genuine victims."
  (Paragraph 33, Judgment)