Shobhit Kumar Mittal v. State of Uttar Pradesh 2025 INSC 1152- S.498A IPC - Cruelty - General Allegations Of Harassment
Indian Penal Code 1860 - Section 498A - The term “cruelty” cannot be established without specific instances. The tendency of invoking the aforesaid provisions, without mentioning any specific detail, weakens the case of the prosecution and casts serious aspersions on the probability of the version of the complainant. Therefore, this Court cannot ignore the missing specifics in the FIR which is the basic premise for invoking the criminal machinery of the State. In such cases involving allegations of cruelty and harassment, there would normally be a series of offending acts, which would be required to be spelt out by the complainant against perpetrators in specific terms to initiate criminal proceedings against them. Therefore, mere general allegations of harassment without pointing out the specific details would not be sufficient to continue criminal proceedings against any person. (Para 18)
Case Info
Case Name and Neutral Citation
- Case Name: Shobhit Kumar Mittal v. State of Uttar Pradesh & Another
- Neutral Citation: 2025 INSC 1152
Coram (Judges)
- Coram: Hon’ble Justice B.V. Nagarathna and Hon’ble Justice R. Mahadevan
Judgment Date
- Date of Judgment: 24 September 2025
Caselaws and Citations Referred
- State of Haryana vs. Bhajan Lal, 1992 Suppl (1) SCC 335
- The judgment refers to paragraph 102 of Bhajan Lal, which lays down categories of cases where powers under Article 226 or Section 482 CrPC can be exercised to quash criminal proceedings.
- Dara Lakshmi Narayana vs. State of Bihar, (2025) 3 SCC 735
- The judgment quotes observations regarding the tendency to implicate family members in matrimonial disputes without specific allegations.
Statutes/Laws Referred
- Indian Penal Code, 1860 (IPC)
- Section 323: Punishment for voluntarily causing hurt
- Section 498A: Cruelty by husband or relatives of husband towards wife
- Dowry Prohibition Act, 1961
- Section 3: Penalty for giving or taking dowry
- Section 4: Penalty for demanding dowry
- Code of Criminal Procedure, 1973 (CrPC)
- Section 41A: Notice of appearance before police officer
- Section 482: Inherent powers of High Court
- Constitution of India
- Article 226: Power of High Courts to issue certain writs
#SupremeCourt holds that “cruelty” cannot be established without specific instances and mere general allegations of harassment not sufficient for criminal proceedings under Section 498A IPC ! https://t.co/8ib5SpeUr5 pic.twitter.com/zSNmU5nkkU
— CiteCase 🇮🇳 (@CiteCase) September 25, 2025
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