Charul Shukla vs State of UP (2026)
Supreme Court of India
CRIMINAL APPEAL NO. OF 2026
(Arising out of Special Leave Petition (Criminal) No.555 of 2024)
Facts of the Case
The present case arose from matrimonial disputes between the complainant and her husband’s family. The complainant married Utkarsh Awasthi on 16 April 2017 according to Hindu rites.
She alleged that:
- Soon after marriage, her husband and in-laws demanded ₹8.5 lakh and a car as dowry.
- She was subjected to continuous harassment and cruelty due to non-fulfilment of dowry demands.
- Her sister-in-law allegedly instigated her husband by accusing the complainant of having an illicit relationship.
- In July 2017, when she was pregnant, her husband and in-laws allegedly assaulted her, leading to miscarriage.
- During Diwali in October 2017, her father-in-law allegedly behaved in a sexually inappropriate manner.
- On 12 November 2023, she was allegedly assaulted, her jewellery was taken, and she was forced to leave her matrimonial home.
Based on these allegations, FIR No. 758/2023 was registered under:
- Sections 498A, 323, 313 IPC
- Sections 3 and 4 Dowry Prohibition Act
Later, the police filed a chargesheet under:
- Sections 323, 354, 498A IPC
- Sections 3 and 4 Dowry Prohibition Act
The appellants (sister-in-law and parents-in-law) approached the Allahabad High Court seeking quashing of FIR, which was dismissed. They then appealed to the Supreme Court.
Issues Before the Court
- Whether the FIR and criminal proceedings disclosed a prima facie case against the sister-in-law and parents-in-law.
- Whether vague, omnibus allegations without supporting evidence are sufficient to continue criminal prosecution.
- Whether the delay of over six years in lodging the FIR rendered the prosecution unreliable.
- Whether the case fell within the categories laid down in State of Haryana v. Bhajan Lal permitting quashing of criminal proceedings.
Arguments by the Appellants (Accused)
The appellants contended that:
- They were falsely implicated due to matrimonial discord between the complainant and her husband.
- The sister-in-law had been living separately and was a college professor, making her involvement improbable.
- The parents-in-law were senior citizens aged 73 and 71 years, living separately.
- The FIR was lodged after six years and seven months, without any explanation.
- Allegations regarding miscarriage were unsupported by medical evidence and were dropped during investigation.
- Allegations of molestation against the father-in-law were vague and lacked specific details.
They argued that continuation of prosecution would be an abuse of process of law.
Arguments by the State
The State argued that:
- The FIR disclosed cognizable offences and therefore investigation and trial should proceed.
- At the stage of quashing, the court should not evaluate evidence but only see whether allegations disclose an offence.
- The truth or falsity of allegations should be determined during trial, not at the pre-trial stage.
Notably, the complainant did not appear before the Supreme Court despite being served notice.
Court’s Analysis
1. Delay in Lodging FIR
The Court found that the FIR was lodged after more than six years from the alleged incidents. The complainant failed to provide a satisfactory explanation for such delay.
The Court emphasised the principle:
“Vigilantibus non dormientibus jura subveniunt” – the law assists those who are vigilant.
The unexplained delay was considered fatal to the prosecution because:
- Evidence becomes unreliable over time
- Matrimonial disputes already suffer from lack of independent evidence
2. Lack of Specific Allegations Against In-laws
The Court observed that:
- Allegations against the sister-in-law were general and omnibus, without specific acts attributed to her.
- Mere naming of relatives in matrimonial disputes cannot justify criminal prosecution.
The Court relied on its earlier ruling cautioning against the misuse of Section 498A IPC by roping in all family members without evidence.
3. Alleged Miscarriage Not Supported by Evidence
The FIR alleged that the accused assaulted the complainant leading to miscarriage. However:
- No medical records supported this claim.
- The investigating officer dropped the charge under Section 313 IPC in the chargesheet.
- Medical examination did not show injuries supporting the allegation.
Thus, the Court held that the allegation lacked evidentiary backing.
4. Allegation of Outraging Modesty (Section 354 IPC)
The complainant alleged that her father-in-law held her hand and behaved inappropriately.
The Court held:
- No specific act constituting outraging of modesty was described.
- Neither FIR nor chargesheet contained material to support this serious allegation.
Therefore, the essential ingredients of Section 354 IPC were not made out.
5. Absence of Evidence of Dowry Demand
The Court noted that:
- Apart from bare statements, no material was produced to prove dowry demands.
- No contemporaneous complaint, message, or witness supported the allegations.
Mere assertion without corroboration was held insufficient to prosecute relatives of the husband.
6. Applicability of Bhajan Lal Principles
The Court held that the case fell within several categories laid down in State of Haryana v. Bhajan Lal, particularly:
- Allegations do not disclose a prima facie offence.
- Allegations are inherently improbable.
- Proceedings appear to be malicious and an abuse of process.
Final Judgment
The Supreme Court:
- Allowed the appeals
- Set aside the Allahabad High Court’s order refusing to quash proceedings
- Quashed:
- FIR No. 758/2023
- Chargesheet dated 18.02.2024
- Criminal Case No. 634/2025
However, the quashing was limited only to the sister-in-law and parents-in-law, and did not affect proceedings against the husband or other matrimonial cases between the parties.
Key Legal Principles Evolved
- Long and unexplained delay in matrimonial offences can weaken prosecution.
- Vague allegations against in-laws are insufficient to sustain prosecution under Section 498A IPC.
- Serious allegations like miscarriage or molestation must be supported by medical or documentary evidence.
- Courts must prevent misuse of criminal law as a tool in matrimonial disputes.