Rahul Gupta & ORS. v. Govt. Of NCT Of Delhi & ANR.

$~61 * IN THE HIGH COURT OF DELHI AT NEW DELHI + CRL.M.C. 8598/2025, CRL.M.A. 35946-35947/2025 RAHUL GUPTA & ORS.

.....Petitioners Through:

Mr. Sachin Yadav, Mr. Gyanadutta Chouhan and Mr. Rayyan Muzeeb, Mr. Rahul Gupta, Advocates for P-1 to 3.

versus GOVT. OF NCT OF DELHI & ANR.

.....Respondents Through:

Mr. Satinder Singh Bawa, APP for State.

SI Manish and ASI Joginder, PSInderpuri.

CORAM:

HON'BLE MR. JUSTICE SANJEEV NARULA

O R D E R

% 03.12.2025 1.

The Petitioners are arraigned in FIR No. 178/2024 registered at P.S. Inderpuri for offences under Sections 498A/406/34 of the Indian Penal Code, 1860.

2.

The Petitioners seek quashing of the FIR. It is contended that the allegations are vague, omnibus and do not disclose any specific role attributable to them. In particular, it is urged that Petitioner No. 3, who is the complainant's sister-in-law, has been deliberately implicated despite not residing in the matrimonial home of the complainant. The FIR is alleged to have been lodged only to harass the family and is stated to be false and frivolous. It is also pointed out that in the domestic violence proceedings instituted by Respondent No. 2, even notice has not been issued to Petitioner The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

No. 3, which, according to the Petitioners, reinforces their plea of false implication.

3.

The Petitioners rely on precedents of the Supreme Court laying down that the power to quash criminal proceedings can be exercised where the allegations are manifestly absurd, inherently improbable or do not disclose the commission of any offence even if taken at face value. They submit that the present case falls within such category, and that continuance of the proceedings would amount to misuse of the criminal process. They also emphasise that in matrimonial disputes, there is recognised judicial concern regarding tendency to implicate the husband's relatives in a sweeping manner, without any clear articulation of distinct acts of cruelty or misappropriation of dowry.

4.

The State, on the other hand, submits that investigation stands concluded and a chargesheet has been filed. It is contended that the Investigating Officer, after examining the complainant and other witnesses, has found sufficient material to place all the Petitioners in the array of accused, and that there are specific allegations concerning harassment and demand of dowry which have led to cognizance being taken. The State submits that the issues sought to be raised in the present petition necessarily require appreciation of evidence and cross-examination of witnesses, which falls within the domain of the Trial Court and not in proceedings for quashing at the pre-trial stage.

5.

It is not in dispute that the Petitioners have already been summoned in the complaint case arising from the FIR, and compliance under Section 207 Cr.P.C. stands completed. The matter is thus at the stage where the Trial Court is to consider arguments on the point of charge. At this juncture, the The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

Trial Court will have before it the FIR, the statements recorded during investigation, and the other material accompanying the chargesheet. That Court will be in a position to assess, in a focused manner, whether the allegations, taken with the material collected, disclose the ingredients of the offences alleged, and whether each Petitioner ought to be put to trial. 6.

Interference at the pre-trial stage is warranted only where, on a plain reading of the FIR and the accompanying material, no offence is disclosed, or where the allegations are so inherently improbable that no reasonable person could draw an inference of guilt. In the present case, the Petitioners have raised contentions that may bear on the ultimate assessment of culpability, such as the nature and specificity of allegations and the residential status of Petitioner No. 3. However, these are issues that can appropriately be urged before the Trial Court while arguing on charge, where the entire factual matrix can be examined. 7.

In that backdrop, this Court does not consider it appropriate to undertake, in proceedings of this nature, a detailed scrutiny of the factual allegations. It would be open to the Petitioners to press all the grounds raised in this petition before the Trial Court at the stage of arguments on charge. The Trial Court shall, at that stage, examine the material accompanying the chargesheet and consider whether the ingredients of the offences are made out against each of the Petitioners. The case law cited by the Petitioners in support of their plea of false implication may also be placed before the Trial Court, which shall consider the same in accordance with law and pass a reasoned order on charge.

8.

In the event the order on charge is adverse to the Petitioners, it will be open to them to avail such remedies as may be available in law against that The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

order, including by way of appropriate proceedings before the competent forum.

9.

In view of the above, and while reserving all rights and contentions of the parties, the present petition is disposed of, along with the pending application(s), if any.

SANJEEV NARULA, J DECEMBER 3, 2025 nk The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.