LexMUSKAN versus ISHAAN KHAN (SATANIYA) AND OTHERS
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[2025] 11 S.C.R. 273 : 2025 INSC 1287 Muskan v. Ishaan Khan (Sataniya) and Others (Criminal Appeal No. 4752 of 2025) 06 November 2025 [Sanjay Karol and Prashant Kumar Mishra,* JJ.] Issue for Consideration 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 s.482 of the Cr.PC. Headnotes† Code of Criminal Procedure, 1973 – s.482 – Marriage between the appellant and respondent no.1 was solemnized in accordance with Muslim traditions and customs – After 5-6 months of the marriage, the private respondents started harassing the appellant for dowry – Due to continuous cruelty faced by the appellant at the hands of the private respondents, she returned to her paternal home and registered an FIR u/s.498A of the IPC and ss.3 and 4 of Dowry Prohibition Act, 1961 against respondent no.1 (husband), respondent no.2 (mother-in-law), respondent no.3 (father-in law), respondent no.4 (sister-in-law) and respondent no.5 (brother-in-law) – It was stated that on 22.07.2021, respondents hurled abuses at her and respondent no.5 slapped her and asked her to bring dowry – Thereafter, on 27.11.2022, respondent No.1, her husband, asked her to bring Rs.50 lakhs from her father – Respondents filed a petition u/s.482 CrPC for quashing of the FIR – The High Court quashed the criminal proceedings – Correctness: Held: On the aspect of the powers of the Courts u/s.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 u/s.482 of the * Author 274 [2025] 11 S.C.R. Supreme Court Reports 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 u/s.482 should not be exercised – 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 considered opinion of this Court, amounts to conducting a mini trial – Accordingly, the present case warrants interference – Thus, the impugned order passed by the High Court is set aside. [Paras 22, 27, 28] Case Law Cited State of Haryana and Others v. Bhajan Lal and Others [1990] 3 Supp. SCR 259 : (1992) Supp. 1 SCC 335; Daxaben v. State of Gujarat and Others [2022] 13 SCR 295 : (2022) 16 SCC 117; State of Odisha v. Pratima Mohanty and Others [2021] 9 SCR 335 : (2022) 16 SCC 703; Central Bureau of Investigation v. Aryan Singh and Others [2023] 2 SCR 819 : (2023) 18 SCC 399; Neeharika Infrastructure Private Limited v. State of Maharashtra and Others [2021] 4 SCR 1044 : (2021) 19 SCC 401; State of Telangana v. Habib Abdullah Jeelani and Others [2017] 1 SCR 141 : (2017) 2 SCC 779 – relied on. Lalita Kumari v. Government of Uttar Pradesh and Others [2013] 14 SCR 713 : (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] 12 SCR 1533 : 2024 SCC OnLine SC 3836; Dara Lakshmi Narayana and Others v. State of Telangana and Another [2024] 12 SCR 559 : (2025) 3 SCC 735 – referred to. List of Acts Penal Code, 1860; Dowry Prohibition Act, 1961. [2025] 11 S.C.R. 275 Muskan v. Ishaan Khan (Sataniya) and Others List of Keywords Section 482 of Cr.PC; Quashing of FIR; Mini trial; Jurisdiction u/s.482 Cr.PC; Dowry; Dowry harassment; Demand of dowry. Case Arising From CRIMINAL APPELLATE JURISDICTION: Criminal Appeal No. 4752 of 2025 From the Judgment and Order dated 19.07.2024 of the High Court of Madhya Pr
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