The Supreme Court recently dismissed a Public Interest Litigation (PIL) challenging the constitutional validity of Section 498A of the Indian Penal Code, now renumbered as Section 84 under the Bharatiya Nyaya Sanhita, 2023. The Court firmly held that the mere possibility of a law’s misuse cannot be a valid reason to strike it down.

“For every such instance, there are likely hundreds of genuine cases where Section 498A has served as a crucial safeguard for victims of domestic cruelty,”
— Supreme Court

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The Court acknowledged that there are growing discussions about misuse of the law. However, it made it clear that one cannot overlook the large number of women who genuinely benefit from this legal protection. It emphasized that the existence of a few false complaints should not undermine the law's critical role in protecting victims.

“Dowry continues to persist as a deeply entrenched social evil... countless women are forced to suffer in silence,”
— Supreme Court

The Court also pointed out that dowry is still widely practiced in India. Many women do not report abuse due to social pressure, fear, or lack of support. This makes Section 498A all the more important.

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A PIL filed by Janshruthi (People's Voice) had requested balanced protection for all parties in matrimonial disputes, including mandatory investigation before registering a case under this section. The bench, however, found no fault in the legislative intent behind the law.

“The provision was enacted in line with Article 15, which empowers the state to protect women and disadvantaged groups,”
— Supreme Court

Rejecting arguments based on Article 14 (equality before law), the Court said the law was a part of positive discrimination aimed at protecting vulnerable groups, especially women.

On the issue of misuse, the Court stated:

“Misuse must be guarded against, but the law cannot be struck down because of it. Courts must examine such claims case-by-case, not based on broad generalizations.”

Case Title: JANSHRUTI (PEOPLE'S VOICE) Versus UNION OF INDIA AND ORS., Diary No. 2152-2025