The Supreme Court ruled that a husband’s financial dominance in a strained marriage does not amount to cruelty. Disputes over expenses reflect “the daily wear and tear of marriage” and do not fall under Section 498 IPC.
New Delhi: The Supreme Court ruled that a husband’s financial dominance over his estranged wife in a deteriorated marital relationship does not constitute an act of cruelty.
The court emphasized that criminal litigation should not serve as a means to settle personal scores or pursue vendettas.
Justices B.V. Nagarathna and R. Mahadevan made these remarks while quashing a criminal case filed by a wife against her estranged husband, which included allegations of cruelty and dowry harassment.
Reversing a decision by the Telangana High Court that had declined to dismiss the FIR, Justice Nagarathna stated,
“The monetary and financial dominance of the accused-appellant, as alleged by the complainant-respondent No. 2, cannot qualify as an instance of cruelty, especially in the absence of any tangible mental or physical harm caused.”
The court recognized that such circumstances reflect a common issue in Indian society, where men typically control household finances.
However, it asserted that criminal litigation should not be a means for personal retribution.
Justice Nagarathna also noted that questioning the spending of money sent by the estranged husband does not amount to cruelty.
The bench remarked,
“The courts have to be extremely careful and cautious in dealing with complaints and must take pragmatic realities into consideration while dealing with matrimonial cases, where the allegations have to be scrutinized with greater care and circumspection in order to prevent miscarriage of justice and abuse of process of law,”
The court described disputes about expenses as indicative of “the daily wear and tear of marriage” and ruled that such conflicts do not fit the definition of cruelty under Section 498 of the Indian Penal Code, which addresses cruelty by a husband or his relatives.
After thoroughly reviewing previous rulings, the court concluded that none of the alleged offenses against the husband were substantiated.
It added,
“In fact, we find that the allegations of cruelty, mental harassment and voluntarily causing hurt against the accused-appellant herein have been made with a mala fide intent with vague and general allegations,”
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This ruling stemmed from an appeal by the husband challenging the April 27, 2023 order of the High Court that had refused to quash the FIR against him and his family.
The Supreme Court also clarified that its observations in this verdict would not interfere with any ongoing matrimonial or other legal proceedings between the parties, which should be resolved based on their merits and in accordance with the law.