Muskan v. Ishaan Khan (Sataniya) 2025 INSC 1287 S.482 CrPC - Quashing - Mini Trial
Code of Criminal Procedure 1973 - Section 482- At the stage of quashing, the Court is not required to conduct a mini trial. Thus, the jurisdiction under Section 482 of the 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 under Section 482 should not be exercised. (Para 22) Normally, for quashing an FIR, it must be shown that there exists no prime facie case against the accused persons. (Para 27) [Context: SC noted that 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. Held: This approach adopted by the High Court, in our considered opinion, amounts to conducting a mini trial.]
Case Info
Key Details
- Case name: Muskan v. Ishaan Khan (Sataniya) and Others.
- Neutral citation: 2025 INSC 1287.
- Coram: Justice Sanjay Karol and Justice Prashant Kumar Mishra.
- Judgment date: November 06, 2025.
- Court/jurisdiction: Supreme Court of India, Criminal Appellate Jurisdiction.
- Appeal number: Criminal Appeal No. 4752 of 2025 (arising out of SLP (Crl.) No. 1531 of 2025).
- Impugned order: High Court of Madhya Pradesh at Indore, dated 19.07.2024 in MCRC No. 10695 of 2024.
Statutes/Laws Referred
- Indian Penal Code, 1860: Section 498A.
- Dowry Prohibition Act, 1961: Sections 3 and 4.
- Code of Criminal Procedure, 1973: Section 482; Sections 156(1), 155(2), 173.
Caselaws and Citations
- State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335.
- Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra, (2021) 19 SCC 401.
- Daxaben v. State of Gujarat, (2022) 16 SCC 117.
- State of Odisha v. Pratima Mohanty, (2022) 16 SCC 703.
- CBI v. Aryan Singh, (2023) 18 SCC 399.
- State of Telangana v. Habib Abdullah Jeelani, (2017) 2 SCC 779.
- Cited by Amicus:
- Lalita Kumari v. Govt. of U.P., (2014) 2 SCC 1.
- Mahmood Ali v. State of U.P., (2023) 15 SCC 488.
- Digambar v. State of Maharashtra, 2024 SCC OnLine SC 3836.
- Dara Lakshmi Narayana v. State of Telangana, (2025) 3 SCC 735.
