Patna High Court

Cognizance in matrimonial disputes quashed following divorce and re-marriage of the informant.

MOST. SAROJ DEVI vs The State of Bihar

Patna High CourtJUDGMENT: April 03, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The informant (Opposite Party No. 2), a resident of Nepal, married the petitioner, Chandan Kumar, on 11.03.2015

Source reference: p.3

Subsequently, she filed two criminal cases (Purnea Mahila P.S. Case No. 45/2016 and Case No. 12/2017) alleging dowry demand of Rs. 5 lakhs, physical torture, and being ousted from her matrimonial home

Source reference: p.3-4

The learned S.D.J.M., Purnea, took cognizance of offences under Sections 341, 323, 498(A), 504/34 of the IPC, the Dowry Prohibition Act, and the Domestic Violence Act

Source reference: p.3

During the pendency of these proceedings, a Family Court in Purnea granted a divorce, and the informant subsequently re-married and withdrew her transfer petitions from the Hon’ble Supreme Court

Source reference: p.4
02

Issues

1. Whether the continuation of criminal proceedings under Section 498(A) IPC and related statutes is sustainable when the parties have divorced and the informant has re-married

Source reference: p.4 / para. 7
03

Law Applied

The court applied the inherent powers under Section 482 of the CrPC to prevent the abuse of the process of law

Source reference: p.4-5

Proceeding with such cases after the dissolution of marriage and re-settlement of the parties would not serve the "interest of justice"

Source reference: p.4
04

Reasoning

Evidence brought on record (Annexure-4) established that the informant had obtained a divorce from the learned Family Court, Purnea, and subsequently re-married

Source reference: p.4

The Court reasoned that her withdrawal of transfer petitions before the Supreme Court and her current marital status suggested she was no longer interested in pursuing the litigation

Source reference: p.4

allowing the prosecution to continue would result in unnecessary harassment for both parties and would be an exercise in futility given the complete severance of the matrimonial bond and the subsequent relocation of the informant to Nepal

Source reference: p.4
05

Holding

The Court held that in light of the divorce and re-marriage, it was not in the interest of justice to proceed with the prosecution

The High Court allowed the petitions and quashed the entire proceedings of Purnea Mahila P.S. Case No. 45 of 2016 and Purnea Mahila P.S. Case No. 12 of 2017

Source reference: p.5

the Court granted the informant liberty to file a review application if she possessed information that could bear upon the outcome of the case

Source reference: p.5
Patna High Court

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MOST. SAROJ DEVIvsThe State of Bihar

Patna High Court · April 03, 2026

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