The Supreme Court of India has upheld the conviction of a man under Section 498A of the Indian Penal Code (IPC) and Section 4 of the Dowry Prohibition Act, 1961 for refusing to cooperate with his wedding reception due to unmet demands for 100 sovereigns of gold as dowry. This decision, while reducing the sentence to time already served, highlights the court's commitment to addressing the pervasive issue of dowry-related harassment.
Case Background
The case originated from a marriage solemnized on March 31, 2006, which lasted only three days. The bridegroom's family had initially agreed to 60 sovereigns of gold for the bride and 10 for the groom. However, days before the wedding, the groom's father demanded 100 sovereigns of gold.
On the day of the reception, the groom’s family continued their demands and disrupted the event. The bride’s relatives pleaded for cooperation, but the groom left the reception dais, refusing to participate until the gold demand was fulfilled. Even the wedding photographer testified that the groom’s family refused to cooperate during the ceremonies.
The bride later lodged a complaint, leading to charges under Section 498A (harassment for dowry) and Section 4 of the Dowry Prohibition Act.
Supreme Court's Findings
The Supreme Court examined testimonies, including that of the bride (PW-4), her mother (PW-7), family friends (PW-1, PW-3), and the photographer (PW-11). It found clear evidence of harassment and coercion linked to the unlawful dowry demand.
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In its judgment, the Court stated:
"The ingredients of Section 498A of IPC are fully satisfied. The appellant subjected PW-4 to harassment with a view to coercing her and her mother to meet the unlawful demand for gold."
However, considering mitigating factors, the Court modified the sentence. These included:
- The passage of 19 years since the incident.
- The couple lived together for only three days.
- Both parties had moved on, with the bride remarried and settled abroad.
- The appellant’s potential as an IT professional to contribute positively to society.
The Supreme Court reduced the appellant’s sentence to the time already served (approximately three months) and directed him to pay ₹3,00,000 as compensation to the bride. The Court emphasized:
"This compensation is to provide redress for the harassment PW-4 endured due to the appellant's actions."
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The compensation is to be deposited in the Trial Court within four weeks, failing which the appeal would be dismissed, and the appellant would be required to serve the remaining sentence.
The judgment referred to Samaul Sk. vs. State of Jharkhand & Anr., where the Court prioritized a reformative approach by reducing the sentence while directing monetary compensation. Similarly, in this case, the Court recognized the value of rehabilitation and societal contribution over prolonged incarceration.
Case Title: M. Venkateswaran Versus The State Rep. by the Inspector of Police
