Legal Review and Analysis of Shobhit Kumar Mittal vs State of Uttar Pradesh & Anr 2025 INSC 1152

1. Name of the Judgment

Shobhit Kumar Mittal vs. State of Uttar Pradesh & Anr.
Criminal Appeal No. ______ of 2025 (Arising out of SLP (Crl.) No. 4069 of 2024)
Decided on: September 24, 2025
Judges: Justice B.V. Nagarathna and Justice R. Mahadevan

Citation:
Shobhit Kumar Mittal vs. State of Uttar Pradesh & Anr., (2025) INSC 1152, Criminal

2. Relevant Laws and Sections

• Indian Penal Code, 1860 (IPC) – Sections 323, 498A

• Dowry Prohibition Act, 1961 – Sections 3, 4

• Code of Criminal Procedure, 1973 (CrPC) – Article 226 of the Constitution of India (Writ Jurisdiction of High Court)

• Precedents Referenced:
  State of Haryana vs. Bhajan Lal, 1992 Supp (1) SCC 335
  Dara Lakshmi Narayana vs. State of Bihar, (2025) 3 SCC 735

3. Basic Details of the Case

• Appellant: Shobhit Kumar Mittal (Brother-in-law of the complainant)

• Respondents: State of Uttar Pradesh and Smt. Jyoti Garg (Complainant)

• Nature of Dispute: Quashing of FIR alleging dowry harassment, cruelty, and physical hurt.

• Forum: Appeal against the order of the Allahabad High Court dated February 27, 2024, which refused to quash the FIR.

• Allegations: Sections 323, 498A IPC and Sections 3, 4 of the Dowry Prohibition Act.

• Supreme Court’s Decision: Quashed the FIR and all proceedings only against the appellant.

4. Core Principle of the Judgment

Issue Before the Supreme Court

Whether the FIR against the brother-in-law contained specific and actionable allegations of cruelty, dowry demand, or physical hurt, or whether it contained only vague and omnibus accusations that did not justify continuation of criminal proceedings.

Background and Matrimonial Dispute

The complainant, Jyoti Garg, married Mohit Mittal on May 1, 2014. Marital discord arose soon after, and she left the matrimonial home. Multiple matrimonial proceedings were initiated between the parties. On November 9, 2023, she filed an FIR against her husband, mother-in-law, and brother-in-law (the appellant), alleging dowry harassment, cruelty, and that such harassment led to a burst blood vessel in her brain, causing paralysis.

Legal Analysis by the Supreme Court

A. Vagueness and Lack of Specific Allegations

The Court scrutinized the FIR and found the allegations to be vague, general, and omnibus. There were no specific instances, dates, places, or details of the alleged harassment or dowry demands attributed to the appellant. The FIR failed to describe any particular role played by the brother-in-law.

B. Ingredients of Sections 323 and 498A IPC Not Met

• Section 323 IPC (Voluntarily Causing Hurt): The Court noted no specific act of violence was attributed to the appellant. The complainant’s medical condition (paralysis) was not directly linked to any act by the appellant.

• Section 498A IPC (Cruelty): The term "cruelty" requires specific wilful conduct likely to drive a woman to suicide or cause grave injury. The FIR contained only general statements without particulars. The Court emphasized that mere mention of family members without specific allegations of active involvement is insufficient to prosecute them.

C. Misuse of Dowry Provisions

Referring to Dara Lakshmi Narayana, the Court observed a growing tendency to misuse Section 498A IPC and dowry laws to implicate all family members in matrimonial disputes. Such general accusations, without concrete evidence, abuse the legal process and harass innocent relatives.

D. Application of Bhajan Lal Guidelines

The Court referred to the categories laid down in State of Haryana vs. Bhajan Lal and held that the case fell under Category (1) and (5):

• Allegations, even if taken at face value, did not constitute a cognizable offence.

• Allegations were inherently improbable and no prudent person would conclude that there was ground to proceed against the appellant.

E. Judicial Caution in Matrimonial Cases

The Court underscored that matrimonial disputes must be scrutinized with great care and circumspection to prevent miscarriage of justice and abuse of the legal process. Courts should nip in the bud any attempt to use criminal law as a tool for vendetta.

5. Final Outcome

The Supreme Court allowed the appeal and set aside the impugned order of the High Court. It quashed the following only qua the appellant (Shobhit Kumar Mittal):

• FIR No. 347 of 2023 dated November 9, 2023

• All consequent proceedings arising therefrom

The Court clarified that its observations shall not affect other pending proceedings between the parties, which shall be decided on their own merits.

6. MCQs Based on the Judgment

Q1. In Shobhit Kumar Mittal vs. State of Uttar Pradesh, on what primary ground did the Supreme Court quash the FIR against the brother-in-law?

A. The complainant withdrew the case
B. The allegations were vague and lacked specific instances against him
C. The brother-in-law was not present in the country
D. The medical evidence was inconclusive

Correct Answer: B
Explanation: The Court held that the FIR contained only general and omnibus allegations without specific details of the appellant’s involvement, which is insufficient to sustain criminal proceedings.

Q2. Which legal principle did the Supreme Court emphasize to prevent misuse of Section 498A IPC?

A. All family members must be arrested immediately
B. Specific allegations of active involvement are necessary to prosecute relatives
C. Matrimonial disputes should be resolved only through mediation
D. FIRs in dowry cases are automatically maintainable against all accused

Correct Answer: B
Explanation: The Court reiterated that mere mention of family members in an FIR without specific allegations of their active role in the alleged cruelty or dowry demand is not enough to prosecute them.