Groom’s Dowry Demand During Wedding Reception: Supreme Court Upholds Conviction Under Section 498A IPC and Dowry Prohibition Act

Post By 24law
January 30, 2025

Pranav B Prem

The Supreme Court recently upheld the conviction of a man under Section 498A of the Indian Penal Code (IPC) and Section 4 of the Dowry Prohibition Act for harassment linked to dowry demands. However, the Court reduced the sentence to the period already served, considering mitigating factors.

Case Background

The case arose from a brief marriage between the appellant, M. Venkateswaran, and his wife, Sridevi (PW-4), which lasted only three days. The marriage, solemnized on March 31, 2006, was overshadowed by the appellant’s family’s persistent demand for dowry. According to evidence presented during the trial, the appellant’s family initially agreed to a dowry of 60 sovereigns of gold for the bride and 10 sovereigns for the groom. However, after the engagement, they increased the demand to 100 sovereigns. On the day of the wedding reception, the appellant refused to participate fully in the ceremony, stating that he would only cooperate if the additional 30 sovereigns were provided. Testimonies revealed that the groom’s family did not allow customary practices during the wedding and even took the groom off the dais during the reception, citing unmet dowry demands.

Evidence and Testimonies

The prosecution relied on the testimonies of multiple witnesses, including:

PW-1 (Samuel): A family friend who confirmed the dowry demand and the appellant’s refusal to participate in the ceremony without receiving 100 sovereigns of gold.
PW-2 (Deepa): The bride’s elder sister, who testified about the appellant’s repeated demands for dowry and his subsequent refusal to cooperate during the reception.
PW-4 (Sridevi): The complainant, who detailed the harassment she endured, including the appellant’s refusal to fulfill marital duties unless the dowry was provided.
PW-11 (Gokulakrishnan): A photographer who corroborated that the appellant’s family refused to cooperate during the wedding photoshoot.

Court’s Findings

The Supreme Court held that the evidence established the appellant’s harassment of his wife to coerce her and her family into meeting unlawful dowry demands. The Bench observed: “We are satisfied that the ingredients of Section 498-A IPC are fully satisfied and that the appellant subjected PW-4 to harassment with a view to coercing her and her mother to meet the unlawful demand for the gold sovereigns and continued to harass her when PW-4 and her relatives failed to meet such demand.”

Sentence Reduction

While upholding the conviction, the Court considered several mitigating factors to reduce the sentence:

The case dated back to 2006, with both parties having moved on in their lives.
The couple had lived together for only three days.
The appellant, an IT professional, was recognized as having the potential to make positive contributions to society.

Referring to the precedent set in Samaul Sk. v. The State of Jharkhand & Anr. (2021), the Court emphasized the importance of reformative criminal jurisprudence. In line with this, the appellant’s sentence was reduced to the period already served, provided he paid monetary compensation to the complainant.

Compensation Awarded

The Court directed the appellant to pay ₹3,00,000 as compensation to the complainant, Sridevi, within four weeks. It noted: “On the special facts of the case, we think the ends of justice will be met if we adopt the course followed by this Court in the case of Samaul Sk. v. The State of Jharkhand & Anr. This Court, in that case, while reducing the sentence to that of the period already undergone, recorded the voluntary offer of the appellant to pay a monetary compensation of ₹3,00,000 to the de facto complainant for the benefit of her children. No doubt in the present case, there is no voluntary offer, but we propose to direct payment of compensation.”

Cause Title: M. Venkateswaran Versus The State Rep. by the Inspector of Police