Section 498A IPC — Omnibus Allegations · 4 June 2025
Ghanshyam Soni v. State (Govt. of NCT of Delhi): Supreme Court Quashes Section 498A FIR Built on Vague, Unsupported Allegations
Supreme Court of India · 2025 LiveLaw (SC) 676; 2025 INSC 803
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The complainant, a Delhi Police sub-inspector, married Ghanshyam Soni in 1998. She alleged that soon after marriage her husband and his family, including his mother and five sisters-in-law, demanded ₹1.5 lakh, a car and a separate house as dowry and subjected her to mental and physical cruelty, including threats with a dagger and assault during pregnancy. FIR No. 1098/2002 was registered at PS Malviya Nagar under Sections 498A, 406 and 34 IPC, and cognizance was taken in July 2004. In October 2008 the Sessions Court discharged all the accused as the allegations were time-barred; in April 2024 the High Court reversed that order and reinstated the charges, and the accused appealed.
A Bench of Justice B.V. Nagarathna and Justice Satish Chandra Sharma allowed the appeal and, using Article 142, quashed the FIR and the chargesheet of 27 July 2004. It found the allegations against the mother-in-law and five sisters-in-law vague and generic, without particulars of individual acts, and, citing K. Subba Rao v. State of Telangana, held that relatives cannot be prosecuted on omnibus allegations. It noted that despite the serious allegations, no medical records, injury reports or witness statements were produced and that the complainant had withdrawn an earlier complaint. The Court stressed the need to balance protection of genuine victims against harassment through baseless prosecutions, and held that the complaint, though within limitation, was too vague and unsupported to justify a trial.
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