In Charul Shukla vs State of U.P. & Others (2026), the Supreme Court set aside the Allahabad High Court’s refusal to quash criminal proceedings against the complainant’s sister-in-law and parents-in-law. The case alleged offences under Sections 498A, 323, 354 IPC and Sections 3 & 4 of the Dowry Prohibition Act.

The Court carefully examined whether the allegations—filed after a delay of over six years—were supported by material evidence. It found that the accusations were largely vague, omnibus, and unsubstantiated, particularly against relatives who were either living separately or were senior citizens.

“21. At the same time, the said allegations also have to be juxtaposed with the fact that the complaint was registered by the complainant only on 15.11.2023 i.e. after a delay of more than six years and seven months from the alleged dowry demand. The prosecution has failed to put forth any sufficient cause for such delay and this casts aspersions on their story. At this juncture, we find it apposite to underline the importance of taking an early recourse to pursue and prosecute criminal complaints.”

“22. Time and again, this Court has observed that merely stating certain vague and omnibus allegations without any cogent material evidence to support the same should not become a fillip to jump-start the criminal machinery of the State.”

“23. Upon bare perusal of the Chargesheet No.01/2024 and the medical examination report annexed thereto, no offence under Section 313 of IPC has been made out. The attached medical examination report fails to ascribe or delineate any particular injury that relates to or supports the claim of the complainant either. We must hasten to add that upon completion of the investigation, the investigating officer also deemed it fit to drop the charges under Section 313 of IPC against the accused/appellants.”

“24. It would not be out of place to mention that the delay of almost seven years between the alleged incident and lodgment of the FIR has not been explained sufficiently by the complainant.”

“25. It is merely stated that the father- in-law held her hands and tried to commit obscene acts with her. The complainant has failed to elaborate upon said ‘obscene acts’ allegedly committed by him. It is trite that the FIR cannot be an encyclopaedia of the events but even upon the perusal of the chargesheet as presented by the investigation officer, the counsel for prosecution/State has not been able to substantiate or discern any substantive material in support of the allegation under Section 354 of IPC. At this juncture, it would not be out of place to mention that the complainant herself has failed to enter appearance in the present proceedings despite service of notice upon her. The said non-appearance, despite the service of notice being complete upon her, inevitably draws our attention towards an adverse inference that the complainant herself is indifferent and uninterested in contesting the said appeals.”

Decision

Importantly, the Court emphasized that:

• Mere allegations without supporting evidence cannot justify criminal prosecution.
• Delay in lodging FIR, especially in matrimonial disputes, must be satisfactorily explained.
• Courts must guard against misuse of criminal law to harass family members.

Applying the principles laid down in Bhajan Lal, the Court concluded that continuing the proceedings would amount to abuse of process of law and quashed the FIR and all consequential proceedings against the appellants.

Citation : 2026 INSC 297

Other Sources :

Index of Quash Judgements is here. 

Key Contributor :
Mrs. Suprajaa Rajan B.Com., LL.B., LL.M.
+91-9606345150