Factual Background
In the case of Jayantilal Vadilal Shah v. State of Gujarat the First Information Report against the applicants for the acts punishable under Sections 498-A, 323 and 114 of the Penal Code, 1860, and Section 4 of the Dowry Prohibition Act, was quashed in accordance with a criminal application made under Section 482 of the Code of Criminal Procedure, 1973. The complainant’s situation involved her in-laws harassing her and demanding money after her marriage. They began living apart as a result of the complainant’s husband’s unlawful involvement with another woman. The complainant’s spouse allegedly started hitting her. As a result, a complaint was made against the husband, his in-laws, and the woman who her spouse had an extramarital affair with. In order to have the FIR lodged against them thrown out, the petitioners went to court
Analysis of Court Order
Sandeep N. Bhatt, a single judge bench on the Gujrat high court, approved the appeal and overturned the FIR that had been brought against the applicants.
The Court noted that the complainant’s mother-in-law was incorrectly implicated in the FIR. According to the court, the complainant’s mother-in-law was around 80 years old when the current case was submitted in 2017 as of right now, she must be close to 86 years old. Accordingly, the Court ruled that continuing such proceedings would amount to abuse of the legal system and serve no useful purpose given the age of the complainant’s mother-in-law and the fact that general accusations were made in the FIR only to ensure that she was included in it. Additionally, the court noted that it would cause higher hardships. The Court further stated that it is necessary to guarantee that criminal prosecution is not used as a tool of intimidation, to pursue a personal grudge, or with an ulterior objective to pressure the accused or to settle the score.
The Court also stated that given the current state of affairs in society, complainants often abuse Section 498A, and in such instances, all family members are included in the complaint only with the intention of harassing the family members. In light of this, the Court granted the current motion and dismissed the FIR brought by the complainant against her mother-in-law.