Criminal proceedings quashed against widow over forged marriage allegations under Sections 494, 495, 416, 420, 504, 506 IPC lacking evidence

SC quashed criminal proceedings against appellant initiated by deceased husband's brother alleging forged marriage. Court found no material evidence supporting allegations in FIR registered under Sections 494, 495, 416, 420, 504, 506 IPC. Appellant's marriage was solemnized in 2016, child born in 2017, husband died in 2017. No complaints were made during matrimonial relationship. Allegations arose only after appellant received terminal benefits and compassionate appointment in 2018. Court held continuing proceedings would abuse legal process and cause mental trauma. Criminal proceedings quashed as no prima facie case established.

---

---

Issues:
1. Criminal proceedings quashing under Section 482 Code of Criminal Procedure.

Analysis:
The judgment revolves around the criminal proceedings initiated against the Appellant based on a complaint filed by the brother-in-law of the Appellant. The Appellant's case involves complex marital issues, including her marriage to Shiv Gobind Prajapati, subsequent annulment, and her marriage to Mohd. Shameem Khan under Sharia law. The complaint alleged various offenses under the Indian Penal Code, leading to the filing of a charge-sheet and summoning of the Appellant. The Appellant approached the High Court seeking quashing of the proceedings, which was declined, prompting the appeal before the Supreme Court.

The Appellant's counsel argued that the allegations were baseless and aimed at pressuring her to hand over terminal benefits received after her late husband's demise. It was contended that the criminal proceedings were an abuse of process and causing mental harassment. The State and complainant's counsel argued that a prima facie case existed, justifying the continuation of the proceedings. The Supreme Court examined the principles laid down in previous judgments regarding the exercise of extraordinary powers under Section 482 of the Code of Criminal Procedure.

The Supreme Court analyzed the facts of the case, emphasizing the lack of material to support the allegations made in the complaint. It noted the absence of factual supporting material for the allegations and highlighted that the charge-sheet did not establish how the marriage certificate was forged. The Court concluded that no offense as alleged in the FIR was made out against the Appellant. It was determined that allowing the proceedings to continue would amount to an abuse of process and cause mental trauma to the Appellant. Consequently, the Supreme Court allowed the appeal, quashing the criminal proceedings initiated against the Appellant under the specified sections of the Indian Penal Code.

In summary, the judgment delves into the intricacies of the Appellant's marital history, the allegations made in the complaint, the legal principles governing the quashing of criminal proceedings, and the lack of factual basis to support the charges against the Appellant. The Supreme Court's decision to quash the proceedings was based on the absence of material substantiating the allegations and the potential for the continuation of the proceedings to result in an abuse of the legal process and mental trauma to the Appellant.

---