The Supreme Court has ruled that relatives of a husband cannot be prosecuted under Section 498A IPC for incidents occurring after the marriage has legally ended.
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NEW DELHI : In a significant ruling that reiterates the importance of temporal proximity in matrimonial offences, the Supreme Court of India on April 18, 2025, quashed a criminal case registered against the relatives of a man under Sections 498A, 323, 504, 506 of the Indian Penal Code, 1860, and Section 4 of the Dowry Prohibition Act, 1961.
The Court held that since the alleged incident took place after the dissolution of marriage between the husband and wife, the husband’s relatives could not be prosecuted for cruelty under Section 498A IPC.
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Background of the Case
The case titled Sushila & Ors. v. State of U.P. & Ors. (Neutral Citation: 2025 INSC 505) arose from a criminal complaint filed by a woman who had married the respondent in 2010. The couple initially resided in Kota, Rajasthan, but marital discord soon followed. In October 2010, the woman left her matrimonial home, taking her belongings, including stridhan, and began residing with her parents.
Attempts by the husband to reconcile failed, and he subsequently filed for divorce. An ex parte divorce decree was granted in 2012, officially ending the marital relationship.
Three years later, in 2015, the woman filed an application under Section 156(3) CrPC seeking registration of a criminal case against her husband and his relatives. The Judicial Magistrate took cognizance of the complaint and issued a summoning order against the husband’s relatives, prompting them to seek relief before the High Court under Section 482 CrPC to quash the proceedings.
However, the High Court disposed of the matter without addressing the merits of their plea. Aggrieved, the appellants approached the Supreme Court.
Supreme Court’s Observations
A Division Bench comprising Justice Sanjay Karol and Justice Prashant Kumar Mishra found merit in the appellants’ contentions and noted that the incident allegedly took place on August 16, 2015—three years after the marriage had legally ended. The complainant had accused the relatives of visiting her house in Kota, demanding dowry, threatening her, and forcibly taking away her mangalsutra.
However, the Court found the allegations to be unsubstantiated and logically inconsistent, stating that there was no credible reason for the relatives to approach the complainant for reconciliation or dowry after the marital relationship had ended via a court decree.
The Bench relied on the precedent set in Geeta Mehrotra & Anr. v. State of U.P. & Anr. (2012), where the Court had cautioned against the routine implication of the husband’s relatives in matrimonial disputes without specific allegations.
The Court held:
“Even if such an incident has happened on 16.08.2015, the fact remains that on the said date, the relationship of husband and wife had already come to an end. As such, the appellants, being relatives of the husband, cannot be proceeded against for offences under Section 498A IPC and Section 4 of the Dowry Prohibition Act, 1961.”
Emphasizing that the continuation of criminal proceedings against the husband’s relatives would amount to a vexatious trial, the Supreme Court quashed the complaint. The Bench found that the allegations in the FIR were largely directed at the husband, and no substantial claims had been made against the appellants during the time the marriage was subsisting.
The ruling is yet another reminder that courts must be cautious in permitting criminal proceedings under matrimonial laws, especially when such cases involve extended family members and are filed after the dissolution of the marriage.
Cause Title: Sushila & Ors. v. State of U.P. & Ors (Neutral Citation: 2025 INSC 505)
Appearances:
- For the Appellants: Advocate Bibek Tripathi, AOR P. V. Yogeswaran, Advocate Y. Lokesh
- For the Respondents: AOR Garvesh Kabra, Advocates Vikash Bansal, Pooja Kabra, Nikita Jaju
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