The bench, comprising Justices B V Nagarathna and Satish Chandra Sharma, criticised the misuse of Section 498A IPC and Dowry Prohibition Act provisions, particularly the trend of wives maliciously implicating the husband’s extended family.
New Delhi: The Supreme Court of India has acquitted a man who spent over 20 years fighting a dowry harassment case filed by his estranged wife. The court noted that the allegations were vague, lacked specific incidents, and were not supported by any solid evidence.
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The man had been accused under Section 498A of the Indian Penal Code (IPC) and Sections 3 and 4 of the Dowry Prohibition Act, 1961, which deal with cruelty and dowry demands. However, the Supreme Court found that the wife did not provide any particular incident or clear example of harassment or cruelty.
The judgment was delivered by a bench of Justice B V Nagarathna and Justice Satish Chandra Sharma. The bench expressed serious concern about the misuse of protective laws in matrimonial cases.
“We are distressed with the manner, the offences under Section 498A IPC, and Sections 3 & 4 of the D.P. Act, 1961 are being maliciously roped in by complainant wives, insofar as aged parents, distant relatives, married sisters living separately, are arrayed as accused, in matrimonial matters”.
The court made it clear that charges of dowry harassment and cruelty cannot be ambiguous or baseless.
“The term ‘cruelty’ is subject to rather cruel misuse by the parties, and cannot be established simpliciter without specific instances, to say the least”.
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In the judgment delivered on May 13, Justice Sharma noted that the trend of filing vague complaints without proper details weakens the case and raises serious doubts about the truthfulness of the allegations.
“The tendency of roping these sections, without mentioning any specific dates, time or incident, weakens the case of the prosecutions, and casts serious suspicion on the viability of the version of a complainant”.
The bench further said that a criminal case cannot proceed if key details are missing from the complaint.
“Be that as it may, we are informed that the marriage of the appellant has already been dissolved and the divorce decree has attained finality, hence any further prosecution of the appellant will only tantamount to an abuse of process of law”.
The Supreme Court was hearing an appeal against a judgment of the Allahabad High Court, which had upheld a 2004 conviction by the Additional Sessions Judge, Lucknow. That decision was based on an appeal from an order by the Chief Judicial Magistrate, who had convicted the man under Section 498A IPC and Section 4 of the Dowry Prohibition Act.
But the Supreme Court held that the wife’s allegations were vague and general, and did not meet the legal standard required to prove cruelty or dowry harassment.
“The allegations made by the complainant are vague, omnibus, and bereft of any material particulars to substantiate this threshold”.
The court observed that the only specific allegation — that the woman had a miscarriage after being pushed out of the house — was also not supported by any medical evidence.
“It is alleged that the complainant suffered a miscarriage, as she fell down, when the appellant and her family pushed her out of the house; however, no medical document from any medical institution or hospital or nursery was produced to substantiate the allegations”.
The court also criticised the High Court for not using its powers earlier to examine whether the FIR and the case itself should have been continued.
“The High Court was well within its revisionary powers to discern whether an FIR and the proceedings emanating therefrom were sustainable. In all certainty, it could have saved 6 years worth of time for the appellant, who has endured litigation for over 20 years as of today”.
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The case began in December 1999, when the wife lodged an FIR at the Women Police Station, Lucknow, accusing her husband and in-laws of mental and physical torture for not giving enough dowry. The couple had been married since February 1997.
The Supreme Court’s ruling brings relief to the man after two decades of legal struggles, while also highlighting how false and vague allegations can lead to misuse of the legal system and unjust suffering for innocent people, especially elderly and distant relatives who are unnecessarily dragged into such cases.
Case Title: RAJESH CHADDHA VERSUS STATE OF UTTAR PRADESH
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