Supreme Court highlights growing misuse of Section 498A IPC, warning that husbands and mothers-in-law increasingly face false complaints, urging scrutiny of matrimonial cases to prevent harassment.
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NEW DELHI: The Supreme Court of India delivered a landmark judgment quashing criminal proceedings against a man accused under Section 498A of the Indian Penal Code (IPC). The ruling underscores the judiciary’s growing concern over the misuse of anti-dowry provisions in cases where allegations are vague or unsubstantiated.
The Court emphasized the misuse of Section 498A IPC, stating that “husbands and mothers-in-law fear false complaints“.
Background of the Case
The case arose from a matrimonial dispute. The complainant married the appellant’s brother on May 1, 2014, but left her matrimonial home after a few months due to discord.
On November 9, 2023, she lodged an FIR at Police Station Civil Lines, Meerut, against her husband, mother-in-law, and brother-in-law (the appellant). The FIR invoked:
- Sections 323 and 498A of the IPC, and
- Sections 3 and 4 of the Dowry Prohibition Act, 1961.
The primary allegations included:
- Harassment for dowry within ten days of marriage.
- Being forced to sign a consent letter along with her relatives to continue living at the matrimonial home.
- A brain vein burst in December 2022, allegedly caused by repeated dowry harassment, resulting in paralysis of her right hand and leg.
High Court’s Decision
The appellant, along with his mother and brother, filed a petition before the Allahabad High Court seeking the quashing of the FIR. The High Court dismissed the petition on February 27, 2024, stating that
“A prima facie case of commission of a cognizable offence was made out.”
Supreme Court Analysis
The Supreme Court bench, comprising Justice B.V. Nagarathna and Justice R. Mahadevan, meticulously examined the FIR to determine whether the allegations were sufficient to sustain criminal proceedings.
The Court noted,
“A bare perusal of the FIR shows that the allegations made by the complainant are vague and omnibus. She has not provided any specific details or described any particular instance of harassment.”
Regarding Section 323 IPC, the Court held,
“There is no remote or proximate act attributed to the accused/appellant that implicates him in the offence of hurt.”
The Court cautioned,
“There is a growing tendency to misuse provisions like Section 498A IPC as a tool for unleashing personal vendetta against the husband and his family.”
Citing State of Haryana vs. Bhajan Lal (1992), the Court reiterated that allegations which do not prima facie constitute an offence fall within the category for quashing. It also referenced Dara Lakshmi Narayana vs. State of Bihar (2025), emphasizing that
“generalized and sweeping accusations unsupported by concrete evidence cannot form the basis for criminal prosecution.”
The Court directed the wife, husband, and mother-in-law to participate in mediation to resolve their disputes amicably, highlighting that the law should facilitate reconciliation wherever possible.
Case Title:
Shobhit Kumar Mittal versus State of Uttar Pradesh
Special Leave Petition (Criminal) No.4069 of 2024
Read Judgment: