Priya Vrat Singh & Ors vs Shyam Ji Sahai

The Supreme Court upheld the dismissal of the application under Section 482 Cr.P.C. for quashing criminal proceedings against the appellants for alleged offences under Sections 494, 120B, and 109 IPC, and Sections 3 & 4 of the Dowry Prohibition Act, 1961. The Court held that the marriage of appellant No. 1 with appellant No. 3 is protected under Section 15 of the Hindu Marriage Act, 1956, making the proceedings under Section 494 IPC not maintainable. The Court also noted the delay in raising dowry allegations, which were made for the first time in December 1994, despite the events occurring in 1992, thus questioning the credibility of the complaint.