The Supreme Court of India recently acquitted a husband in a 26-year-old case involving charges of cruelty and dowry under Section 498A of the Indian Penal Code (IPC) and Section 4 of the Dowry Prohibition Act, citing a lack of credible evidence. The judgment emphasized concerns about the "cruel misuse" of Section 498A by complainants.
The bench of Justices BV Nagarathna and SC Sharma observed that allegations of cruelty are often misused without concrete evidence. The court stated:
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“The term ‘cruelty’ is subject to rather cruel misuse by the parties, and cannot be established simpliciter without specific instances, to say the least. The tendency of roping these sections, without mentioning any specific dates, time, or incident, weakens the case of the prosecution and casts serious suspicion on the viability of the version of a Complainant.”
Case Background
- Year of FIR: 1999
- Accusations: The wife alleged physical and mental cruelty, including assault, forced consumption of narcotics, and dowry demands of ₹2 lakhs. She further claimed a miscarriage due to assault but provided no medical evidence.
- Duration of Cohabitation: The couple lived together for just 12 days after their marriage.
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The court highlighted that the allegations were vague and lacked specifics, such as dates, times, and independent witnesses. Justice Sharma, authoring the judgment, noted that the case was based on generalized accusations rather than clear, verifiable facts.
The judgment also referred to the court's decision in Dara Lakshmi Narayana & Ors. v. State of Telangana & Anr., reiterating the growing misuse of Section 498A IPC. The court expressed concern over complainants wrongly accusing not just the husband but also his relatives, including aged parents and distant family members.
“Notwithstanding the merits of the case, 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.”
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Considering the lack of credible evidence and the misuse of legal provisions, the Supreme Court allowed the appeal, acquitting the husband. The court also noted that the couple's marriage had already been dissolved and any further prosecution would be an "abuse of process of law."
“We cannot ignore the missing specifics in a criminal complaint, which is the premise of invoking criminal machinery of the State.”
Case Title: RAJESH CHADDHA VERSUS STATE OF UTTAR PRADESH
Appearance:
For Petitioner(s) Ms. Preetika Dwivedi, AOR
For Respondent(s) Mr. Shaurya Sahay, AOR Mr. Aditya Kumar, Adv. Ms. Ruchil Raj, Adv.
