The Supreme Court Yesterday (Oct 21) noted that the tendency of over implication is reflected in a large number of cases filed alleging offence under Section 498A IPC and asked the Courts to be cautious about the same. The Court acquitted a man accused under Section 498A IPC while noting that only because he is the husband of guilty sister in law cannot be a ground to hold him guilty under the said offence in the absence of any specific material. The Court was hearing a Criminal Appeal against the decision of the High Court which partly allowed appellant’s appeal whereunder his conviction under Section 498-A of the Indian Penal Code, 1860 was confirmed.
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NEW DELHI: The Supreme Court of India addressed the issue of over-implication in cases involving Section 498A of the Indian Penal Code (IPC), a provision that deals with cruelty to a woman by her husband or his relatives. The Court emphasized the need for caution in handling such cases, as a growing number of them reflect exaggerated allegations.
In this specific instance, the Court acquitted a man accused under Section 498A IPC, noting that his relationship with the guilty party, his sister-in-law, could not serve as sufficient grounds for his conviction without specific evidence to support the charge.
The Court was hearing a Criminal Appeal against a High Court decision that had partially upheld the appellant’s conviction under Section 498A of the IPC.
The bench comprising Justice CT Ravikumar and Justice Sanjay Kumar ruled that the appellant’s conviction was based on a flawed interpretation of the law.
They observed,
“Being the husband of the second accused, Savita, who was found guilty by the courts below for the aforesaid offence, cannot be a ground to hold the appellant guilty under the said offence in the absence of any specific material on record.”
The Court added,
“The finding of guilt against the appellant by the courts below for the offence under Section 498-A, IPC, with the aid of Section 34, IPC, is absolutely perverse in view of the absolute absence of any evidence against him to connect him with the said offence in any manner.”
The Court’s remarks signal a firm stance against the misuse of Section 498A IPC, where innocent parties may be implicated without concrete evidence.
Case Background and Facts
In this case, the second respondent’s daughter was married to the first accused. Allegedly, the accused and his relatives had demanded dowry and subjected the woman to both physical and mental cruelty. One day, the appellant, who is the husband of the deceased’s sister-in-law, informed her father that she had been admitted to the hospital. Unfortunately, by the time her family arrived, she had already passed away.
Upon seeing her body, her father noticed abrasions on her forehead and ligature marks around her neck, which led him to suspect foul play.
A complaint was lodged, resulting in the filing of an FIR and a subsequent trial in which the appellant was also convicted under Section 498A of the IPC.
Legal Observations and Acquittal
The Court took note of the legal precedent set in Preeti Gupta v. State of Jharkhand, a case where the Court had remarked,
“It is a matter of common knowledge that exaggerated versions of the incident are reflected in a large number of complaints and the tendency of over implication is also reflected in a large number of cases.”
This precedent played a crucial role in the Court’s assessment of the current case.
The bench further emphasized,
“The Courts have to be careful to identify instances of over implication and to avert the suffering of ignominy and inexpiable consequences, by such persons.”
This statement highlights the Court’s concern about individuals being wrongfully dragged into legal battles based on weak or nonexistent evidence, especially in cases involving familial relationships.
Based on the absence of substantial evidence linking the appellant to the offence under Section 498A, the Supreme Court allowed the appeal, acquitting him of all charges.
Conclusion
This judgment serves as a significant reminder of the importance of carefully scrutinizing the evidence in cases filed under Section 498A IPC to avoid unnecessary harassment of innocent individuals.
The Supreme Court’s reiteration of its earlier stance in cases like Preeti Gupta v. State of Jharkhand demonstrates the judiciary’s awareness of the increasing misuse of legal provisions meant to protect women from cruelty.
The ruling also highlights the need for judicial prudence in distinguishing between actual perpetrators and those wrongly implicated due to familial ties.
Case Title: Yashodeep Bisanrao Vadode v. The State of Maharashtra
Neutral Citation: 2024 INSC 798
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