Analyzing the Supreme Court Judgment on Safiya Bano alias Shakira v. The State of U.P.: A Case Study in Quashing Criminal Proceedings

In a recent landmark judgment, the Supreme Court of India addressed the intricacies of quashing criminal proceedings in the case of Safiya Bano alias Shakira v. The State of U.P. The case delves into allegations of harassment and dowry demands against the appellants under various sections of the Indian Penal Code. This blog will dissect the legal nuances of the judgment, examining the arguments presented, the scrutiny of evidence, and the ultimate decision of the apex court. Join us as we navigate through the complexities of criminal law and judicial reasoning in this significant legal precedent.


  • The appellants filed a petition under Section 482 of Cr.P.C. to quash the FIR against them for various offenses.
  • The High Court rejected the petition stating that the allegations in the FIR disclosed ingredients for an offense under Section 498-A of IPC.
  • An attempt was made to settle the matter as seen from the settlement agreement between the husband and wife.
  • The settlement agreement included clauses preventing the wife from demanding maintenance or claiming any rights in properties in the future.
  • The petitioners denied specific allegations of ill-treatment, and no harmony could be established due to increased differences.
  • It was mentioned that the FIR was filed to harass the husband and his family after a decree for restitution of conjugal rights was filed.
  • The husband did not appear in the proceedings, and the wife changed her mind about the settlement.
  • No specific allegations of ill-treatment were made against the appellants, and the wife agreed not to demand maintenance in the future.
  • General and bald allegations insufficient to constitute an offense under Section 498-A of IPC against the present appellants.
  • No specific evidence or details provided to demonstrate how the ingredients of the offense are made out against the present appellants.

Also Read: Ravinder Kumar vs. State – Legal Case Summary


  • The appeal has been allowed.
  • Any pending applications have been disposed of.
  • The proceedings related to FIR No. 321 of 2019 at Police Station Thakur Ganj, Lucknow, against the present appellants have been quashed and set aside.
  • It is clarified that proceedings against the present appellants will continue in accordance with the law.

Also Read: Divgi Metal Wares Ltd vs. Divgi Metal Wares Employees Association


Case Number: Crl.A. No.-000512-000512 / 2024

Click here to read/download original judgement

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