(Dipankar Datta and Augustine George Masih, JJ.)
Chennamsetty Venkateswara Rao and Others _____ Appellants(s);
v.
State of Andhra Pradesh and Another ____________ Respondent(s).
Criminal Appeal No. of 2025 [Arising Out of SLP (Crl.) No. 2739 of 2025], decided on December 8, 2025
The Order of the court was delivered by
Order
1. Leave granted.
2. The High Court of Andhra Pradesh at Amaravati, by the impugned judgment and order dated 4th October, 2024, has refused to quash a First Information Report1 registered on a complaint lodged by the respondent no. 2 alleging commission of offences under Sections 498(A), 420, 323, 506 read with Section 34 of the Indian Penal Code, 1860 and Section 4 of the Dowry Prohibition Act, 1961.
3. The appellants figure as A-2, A-3 and A-4 in the F.I.R. They are the in-laws of the daughter2 of the respondent no. 2. The victim was married to the son (A-1) of A-2 and A-3 on 24th February, 2019. Within a month of marriage, the spouses shifted to the United States of America3. It is not in dispute that A-1 has obtained a decree of divorce from a court in the USA on 30th April, 2021. The F.I.R. is dated 16th March, 2020, which was lodged by the respondent no. 2 after A-1 had applied for divorce on 2nd March, 2020. For a major part of the period between the dates of marriage and lodging of the F.I.R., the victim was in the USA.
4. We have heard Mr. K. Parameshwar, learned senior counsel for the appellants and Ms. Prerna Singh, learned counsel for the respondent no. 2. We have also read the written complaint of the respondent no. 2, giving rise to the F.I.R.
5. While it is trite that an FIR need not be an encyclopaedia of all facts, the allegations must nevertheless furnish the foundational particulars necessary to disclose the commission of a cognizable offence. As emphasised in Dara Lakshmi Narayana v. State of Telangana4, vague, sweeping and omnibus assertions, bereft of specific details of the alleged acts, cannot sustain the continued invocation of the criminal law, particularly in matrimonial disputes where the tendency to implicate the opposite party in retaliation is not unknown. It was held there as follows:
30. The inclusion of Section 498-A IPC by way of an amendment was intended to curb cruelty inflicted on a woman by her husband and his family, ensuring swift intervention by the State. However, in recent years, as there have been a notable rise in matrimonial disputes across the country, accompanied by growing discord and tension within the institution of marriage, consequently, there has been a growing tendency to misuse provisions like Section 498-A IPC as a tool for unleashing personal vendetta against the husband and his family by a wife. Making vague and generalised allegations during matrimonial conflicts, if not scrutinised, will lead to the misuse of legal processes and an encouragement for use of arm twisting tactics by a wife and/or her family. Sometimes, recourse is taken to invoke Section 498-A IPC against the husband and his family in order to seek compliance with the unreasonable demands of a wife. Consequently, this Court has, time and again, cautioned against prosecuting the husband and his family in the absence of a clear prima facie case against them.
6. It appears that the complaint lacks the specific details of the alleged incidents of crime and the allegations are vague and omnibus in nature. Given the facts of this case and in view of the timing and context of the F.I.R, together with its contents, we are of the considered opinion that the High Court erred in failing to exercise its inherent powers saved by Section 482, Code of Criminal Procedure, 1973 and thereby has failed to prevent abuse of the court’s process which would ensue by continuance of the criminal prosecution against the appellants.
7. We, accordingly, set aside the judgment and order of the High Court under challenge in this appeal. We also quash all further proceedings in pursuance of the subject F.I.R.
8. We, however, make it clear that proceedings against the victim’s husband (A-1) will continue in accordance with law.
9. The appeal stands allowed.
10. Pending applications, if any, stand disposed of.
SUPREME COURT OF INDIA
RECORD OF PROCEEDINGS
Petition(s) for Special Leave to Appeal (Crl.) No(s). 2739/2025
[Arising out of impugned judgment and order dated 04-10-2024 in CRLP No. 4848/2022 passed by the High Court of Andhra Pradesh at Amravati]
Chennamsetty Venkateswara Rao & Ors.….Petitioner(s)
Versus
State of Andhra Pradesh & Anr.….Respondent(s)
(IA No. 39318/2025 – Exemption from Filing C/C of the Impugned Judgment)
UPON hearing the counsel the Court made the following
ORDER
1. Leave granted.
2. The appeal is allowed in terms of the signed order.
3. Pending applications, if any, stand disposed of.
———
1 F.I.R.
2 victim
3 USA
4 (2025) 3 SCC 735
