Mahakud had approached the court seeking to quash the FIR filed by Kabita Mahakud at the Mahila police station in Bhubaneswar alleging mental and physical torture against the Independent MLA.
Justice B K Nayak refused to interfere at this stage saying police have already started their probe.
The judge, however, gave Sanatan the liberty to approach the court with the same prayer after charge sheet is filed.
In the FIR, Kabita said she had married the MLA's elder son Pankaj in 2012 and they have a child. But neither Pankaj nor his father accepted her claims.