PRATIBHA RANI vs SURAJ KUMAR & ANR.

The Supreme Court held that stridhan, which includes dowry articles, remains the exclusive property of the wife and does not become joint property merely by being in the custody of her husband. The Court clarified that a wife can file a criminal complaint for breach of trust under Sections 405 and 406 IPC against her husband and his relatives for not returning her stridhan. The Court also explained the inherent powers of the High Court under Section 482 of the CrPC to quash FIRs, emphasizing that civil remedies do not bar criminal remedies when both are available.