High Court Quashes FIR Under Section 498-A IPC Against Husband and In-Laws in Matrimonial Discord Case. Allegations of Cruelty Fail Due to Lack of Prima Facie Evidence and Abuse of Process of Law

Sub Category: Bombay High Court Bench: NAGPUR

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2026-02-21 15:03:28

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Case Note & Summary

The Applicants, including the husband and his family members, filed a criminal application seeking quashing of an FIR registered under Section 498-A read with Section 34 of Indian Penal Code, 1860 (IPC) by Non-applicant No.2, the wife. The marriage was solemnized on 15 June 2020, and the couple faced misunderstandings and petty quarrels during cohabitation. The husband had lodged a police report alleging abuse by the wife, and medical evidence showed injuries on him. The wife later became pregnant, and divorce proceedings were initiated. Settlement talks for mutual divorce occurred but failed due to monetary disagreements. The Court examined the material and found the allegations did not prima facie constitute cruelty under Section 498-A IPC, as the disputes were trivial and involved educated individuals. The FIR was quashed under Section 482 of Code of Criminal Procedure, 1973 (CrPC) as an abuse of process of law.

Headnote

The High Court of Judicature at Bombay, Nagpur Bench, quashed the FIR registered under Section 498-A read with Section 34 of Indian Penal Code, 1860 (IPC) against the Applicants -- The Court held that the allegations did not prima facie constitute an offence under Section 498-A IPC -- The matrimonial discord involved trivial quarrels and misunderstandings between educated spouses -- Settlement attempts and mutual divorce discussions were undertaken -- The FIR was found to be an abuse of process of law and lacked essential ingredients for cruelty under Section 498-A IPC -- The Court exercised powers under Section 482 of Code of Criminal Procedure, 1973 (CrPC) to quash the proceedings

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Issue of Consideration: The Issue of Consideration was whether the FIR registered under Section 498-A read with Section 34 of Indian Penal Code, 1860 (IPC) against the Applicants should be quashed under Section 482 of Code of Criminal Procedure, 1973 (CrPC) due to lack of prima facie evidence and abuse of process of law

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Final Decision

The High Court allowed the criminal application and quashed the FIR No. 580/2024 registered under Section 498-A read with Section 34 IPC against the Applicants

2026 LawText (BOM) (02) 95

Criminal Application (APL) No. 1349 of 2024

2026-02-20

Pravin S. Patil J.

2026:BHC-NAG:2909-DB

Mr. A. R. Deshpande, Mr. S. S. Deshpande, Ms. S. V. Kolhe

Vaibhav Gopaldas Mundada, Gopaldas Shankarlal Mundada, Usha Gopaldas Mundada, Aarti Amit Lahoti, Amit Anilkumar Lahoti

State of Maharashtra, Neha Vaibhav Mundada

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Nature of Litigation: Criminal application for quashing of FIR under Section 498-A IPC

Remedy Sought

Applicants sought quashing of FIR No. 580/2024 registered under Section 498-A read with Section 34 IPC

Filing Reason

Allegations of cruelty by wife against husband and in-laws, with Applicants claiming lack of prima facie evidence and abuse of process

Previous Decisions

No previous decisions mentioned; the application was heard and decided by the High Court

Issues

Whether the FIR under Section 498-A IPC should be quashed under Section 482 CrPC due to lack of prima facie evidence Whether the allegations constituted cruelty under Section 498-A IPC or were trivial matrimonial disputes

Submissions/Arguments

Applicants argued that allegations were false and based on matrimonial discord without prima facie evidence of cruelty Non-applicant No.2 argued for maintaining the FIR based on alleged cruelty State represented by APP did not oppose quashing based on material scrutiny

Ratio Decidendi

The Court held that the allegations did not prima facie constitute an offence under Section 498-A IPC as the disputes were trivial quarrels between educated spouses, and the FIR was an abuse of process of law, warranting quashing under Section 482 CrPC

Judgment Excerpts

The present matter reflects an unfortunate discord between the Applicants and Non-applicant No.2/wife, both of whom hail from well educated and respectable families, yet have levelled grave, sweeping and mutually destructive allegation against each other The seriousness and tenor of the accusations, coupled with their far reaching civil and criminal consequences obliged this Court to proceed with utmost circumspection The Applicants have placed on record the sufficient material in the nature of chats on Whatsapp on the mobile in the month of February-2024, whereby the Non-applicant No.2 accepted her guilt and apologised the Applicant, for her behaviour with the Applicant No.1 On this amount, there was a mutual agreement between the parties

Procedural History

FIR registered on 22 February 2024 under Section 498-A read with Section 34 IPC -- Criminal application filed by Applicants seeking quashing -- Heard on 16 February 2026 -- Pronounced on 20 February 2026 -- Rule made returnable forthwith and heard finally with consent