High Courts shall not conduct ‘Mini Trial’ by embarking upon an enquiry about the credibility of the allegations in the complaint and the FIR

Appeal

Appeal against the quash order of offence under section 498A IPC and sections 3 & 4 of DP Act

2. The present Appeal has been preferred against the impugned order dated 19.07.2024 in Misc. Criminal Case No.10695 of 2024 passed by the High Court of Madhya Pradesh at Indore wherein the High Court has quashed the proceedings emanating from FIR No. 35 of 2024 dated 28.01.2024 registered at Police Station Alot, District Ratlam, Madhya Pradesh under Section 498A of the Indian Penal Code, 18601 and Sections 3 and 4 of the Dowry Prohibition Act, 1961 against private respondent Nos.1 to 5 herein.

Analysis

17. The main issue that arises for our analysis is whether the High Court was right in quashing the criminal proceedings against the private respondents primarily on the ground that the earlier complaints did not mention the two specific incidents dated 22.07.2021 and 27.11.2022, which were later on added in the FIR and whether the same would not amount to conducting a ‘mini trial’ which is clearly prohibited under the scheme of Section 482 of the Cr.PC.

Hon’ble Supreme Court, after referring to judgments that have already discussed and settled section 482 Cr.P.C and its use by the High Court, the Supreme Court has held as follows:

22. On the aspect of the powers of the Courts under Section 482 of the Cr.PC, it is settled that at the stage of quashing, the Court is not required to conduct a mini trial. Thus, the jurisdiction under Section 482 of the Cr.PC with respect to quashing is somewhat limited as the Court has to only consider whether any sufficient material is available to proceed against the accused or not. If sufficient material is available, the power under Section 482 should not be exercised.

27. We are of the view that the High Court has erred in law by embarking upon an enquiry with regard to credibility or otherwise of the allegations in the complaints and the FIR. Normally, for quashing an FIR, it must be shown that there exists no prime facie case against the accused persons. In the present case, from the conjoint reading of the complaints and the FIR, it can be seen that prime facie allegations of harassment and demand of dowry are made out, despite that the High Court quashed the FIR against the private respondents primarily on the ground that the earlier two complaints that were filed by the appellant did not mention the specific instances that happened on 22.07.2021 and 27.11.2022 and the same were later on mentioned in the FIR only as an afterthought and was a counterblast to the legal notice sent by respondent no.1/husband to the appellant as she was not coming back to her matrimonial home. This approach adopted by the High Court, in our considered opinion, amounts to conducting a mini trial.

Conclusion

28. Accordingly, in our view, the present case warrants interference by this Court, and we do so. We hereby set aside the impugned order passed by the High Court in Miscellaneous Criminal Case No.10695 of 2024.

29. The Appeal is, accordingly, allowed. All contentions and defences available to the respective parties are kept open which shall be considered by the Trial Court on its own merits and in accordance with law.

Judgments cited or quoted

• Neeharika Infrastructure Private Limited v. State of Maharashtra and Others [(2021) 19 SCC 401]
• State of Haryana and Others v. Bhajan Lal and Others [1992 Supp (1) SCC 335]
• Lalita Kumari v. Government of Uttar Pradesh and Others [(2014) 2 SCC 1]
• Mahmood Ali and Others v. State of Uttar Pradesh and Others [(2023) 15 SCC 488]
• Digambar and Another v. State of Maharashtra and Another [2024 SCC OnLine SC 3836]
• Dara Lakshmi Narayana and others v. State of Telangana and Anothers [(2025) 3 SCC 735]
• Daxaben v. State of Gujarat and Others [(2022) 16 SCC 117]
• Monica Kumar v. State of U.P. [(2008) 8 SCC 781 : (2008) 3 SCC (Cri) 649]
• Dhanalakshmi v. R. Prasanna Kumar [1990 Supp SCC 686 : 1991 SCC (Cri) 142 : AIR 1990 SC 494]
• State of Odisha v. Pratima Mohanty and Others [(2022) 16 SCC 703]
• Central Bureau of Investigation v. Aryan Singh and Others [(2023) 18 SCC 399] ¹¹
• State of Telangana v. Habib Abdullah Jeelani and Others [(2017) 2 SCC 779] ¹²
• Kurukshetra University v. State of Haryana [(1977) 4 SCC 451: 1977 SCC (Cri) 613] ¹³ (This case was quoted within the State of Telangana v. Habib Abdullah Jeelani judgment).

Party

Muskan vs. Ishaan Khan (Sataniya) and Others - Criminal Appeal No. 4752 of 2025 (arising out of SLP (Crl.) No. 1531 of 2025) - 2025 INSC 1287 - November 6, 2025 Hon’ble Mr. Justice Justice Sanjay Karol and Hon’ble Mr. Justice Prashant Kumar Mishra.