The Bombay High Court in Tushar Sampat Mane and Ors Vs State of Maharashtra on 8 Aug 2025 held that courts must quash criminal proceedings when allegations fail to meet the legal threshold of cruelty under Section 498A IPC. The Court found that the allegations were exaggerated, omnibus, and not grave in nature.

It further observed that prior knowledge of the husband’s medical condition weakens claims of suppression. Additionally, routine marital discord or trivial disputes cannot amount to cruelty.

Therefore, the Court concluded that continuation of criminal proceedings would amount to abuse of process of law.

“5. Therefore, either the case may come under Explanation (a) or Explanation (b) or in some cases it may be both. But such cruelty then should be of a grave nature.”

“5. Now, except the statement of informant there is nothing in the charge sheet. The Investigating Officer has not even taken care to make inquiry with the neighbours of applicants regarding the treatment given by applicants to informant.”

“5. Making annoying statements that informant was not wearing proper clothes, was not able to cook food properly, cannot be said to be acts of grave cruelty or harassment.”

“7. When the relationship gets strained, it appears that exaggerations are made.”

“7. When everything was disclosed prior to the marriage and allegations are omnibus or of not so grave for befitting in the concept of cruelty contemplated under Section 498-A of the Indian Penal Code, it would be an abuse of process of law if the applicants are asked to face the trial.”

Decision

The Court allowed the criminal application. It quashed Regular Criminal Case under Sections 498A, 323, 504, 506 read with Section 34 IPC (corresponding provisions under BNS).

The Court held that allegations lacked gravity and specificity. It further held that continuation of proceedings would amount to abuse of process of law.

Citation :2025:BHC-AUG:21166-DB

Other Sources :

Index of Quash Judgment u/s 482 Cr.P.C is here.

Key Contributor : 

Mrs. Suprajaa Rajan B.Com., LL.B., LL.M.

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