(Para 1):
Title & Case:
The applicants sought to quash FIR No. 391/2020 dated 14.08.2020 under Sections 498-A, 323, 504, 506 r/w 34 IPC, and a charge-sheet/final report No. 50/2021 in RCC No. 230/2021, Nanded, under Section 482 CrPC.

(Para 2-4):
FIR Details & Allegations:
The deceased Shraddha married Swapnil Kosalge on 07.05.2019. Within seven days of marriage, demands for Rs. 5,00,000 and Rs. 20,00,000 were made by in-laws. Later, Shraddha and Swapnil moved to the USA, where Shraddha allegedly faced ill-treatment, including starvation and assault. She informed her parents about Swapnil's extramarital affair. Shraddha died in the USA on 04.11.2019, allegedly due to negligence. Her in-laws failed to provide medical records after her death.

(Para 5-6):
Applicants’ Defense:
The applicants (in-laws, mediators, and brother-in-law) claimed Shraddha died of a congenital heart condition (aortic dissection) as per the postmortem. The defense highlighted a delay of nine months in lodging the FIR and suggested the case was lodged out of vengeance after disputes over life insurance benefits.

(Para 7-9):
Postmortem Evidence:
The postmortem from the USA declared Shraddha’s death as natural, citing "ruptured aortic dissection." The applicants argued that there was no dowry demand or cruelty as defined under Section 304-B IPC.

(Para 10-11):
Legal Provisions:
For a dowry death under Section 304-B IPC, it is necessary to prove that the death occurred otherwise than under normal circumstances and within seven years of marriage, and that cruelty or harassment for dowry occurred soon before death. The court found that Shraddha’s death was natural and that the ingredients of Section 304-B IPC were not met.

(Para 12-13):
Observations:
The court observed that Shraddha stayed only nine days at her matrimonial home in India before moving to the USA. There were no complaints filed by her parents during their visit to the USA. The delay of 10 months in lodging the FIR, the lack of evidence of cruelty or dowry harassment, and the natural cause of death pointed to a possible misuse of legal proceedings.

(Para 14-15):
Precedents & Conclusion:
The court referred to Supreme Court judgments, including Preeti Gupta vs. State of Jharkhand, to caution against the misuse of Section 498-A IPC. Since no triable case was made out against the applicants, the court quashed the FIR and charge-sheet.

Legal Provisions & Sections Discussed

• Section 482 CrPC: Inherent powers to quash proceedings where there is abuse of legal process.
• Section 304-B IPC: Dowry death—requires unnatural death within seven years of marriage due to dowry-related harassment.
• Sections 498-A, 323, 504, 506 IPC: Relating to cruelty, physical harm, and criminal intimidation.
• Judicial Precedents:
  • Satbir Singh vs. State of Haryana
  • Preeti Gupta vs. State of Jharkhand
  • Kahkashan Kausar vs. State of Bihar

Ratio & Analysis

• Lack of Evidence: No material evidence of dowry demands or cruelty before death.
• Natural Death: Medical records and postmortem established natural death due to aortic dissection.
• Delay in FIR: Unexplained delay of 9-10 months in filing the FIR raised doubts about the veracity of the allegations.
• Jurisdiction Misuse: The court found that the FIR was lodged as retaliation following a succession certificate dispute, amounting to misuse of criminal law in matrimonial cases.

Subjects

• Section 482 CrPC
• Section 304-B IPC
• Dowry Death
• Misuse of 498-A
• Natural Death
• Matrimonial Disputes