Pranav B Prem

The Supreme Court has reiterated that criminal law should not be used as a tool for harassment or personal vendetta, emphasizing the need for courts to exercise caution in cases involving allegations under Section 498-A of the Indian Penal Code (IPC) and the Dowry Prohibition Act. The Court quashed criminal proceedings against the husband and his parents stating that the allegations were vague and unsubstantiated.

Background of the Case

The case originated from an FIR registered against the husband and his parents under Sections 498-A, 504, 506 of IPC, Sections 3 and 4 of the Dowry Prohibition Act, and Sections 3(1)(r), 3(1)(s), and 3(1)(w) of the Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act. The complainant alleged that she was subjected to cruelty and dowry demands. The High Court, in its order dated September 15, 2023, quashed proceedings under Sections 504 and 506 IPC and the SC/ST Act but refused to quash the case under Section 498-A IPC and the Dowry Prohibition Act, prompting the appellants to approach the Supreme Court.

Supreme Court’s Observations

A bench comprising Justices Vikram Nath and Sandeep Mehta noted that the Family Court had already granted a divorce to the appellant-husband, finding that the complainant had made "several bald and baseless allegations against him and thereby treated him with cruelty." The Court found that the allegations against the in-laws were general and lacked specificity. It observed: "The complainant has not provided any concrete details of dowry demands or acts of cruelty attributable to them. The admitted fact of their separate residence further weakens the complainant's case against them. In the absence of prima facie evidence to establish their involvement in the alleged offenses, the proceedings against the father-in-law and mother-in-law cannot be sustained.”

Regarding the allegations against the husband, the Court noted that they were vague and unsubstantiated, with no material evidence to establish a prima facie case: "No specific allegations and neither any material have come on record to show a prima facie commission of the alleged offences of cruelty and dowry demand. The couple had a love marriage and experienced a blissful relationship during the initial years of their marriage, as is admitted on record. This, coupled with the lack of material evidence to support the allegations, leads to the conclusion that no prima facie case of cruelty or dowry demand is made out against the husband as well."

Misuse of Criminal Law

The Court strongly cautioned against the misuse of legal provisions meant for the protection of women, stating: "Criminal law should not be used as a tool for harassment or vendetta. The allegations in a criminal complaint must be scrutinized with care to ensure that they disclose a prima facie case before subjecting individuals to the rigors of a criminal trial. The cases involving allegations under Section 498-A of the IPC and the DP Act often require a careful and cautious approach to prevent misuse of the law. While the provisions are intended to protect women from cruelty and dowry harassment, they should not be used to settle personal scores or pursue ulterior motives.”

Verdict

Finding the allegations baseless, the Supreme Court held: "In the present case, the allegations against the appellants were devoid of merit, manifestly frivolous and fail to disclose a prima facie case. The continuation of criminal proceedings in such circumstances would amount to an abuse of the process of law and result in a miscarriage of justice.” Accordingly, the Court allowed the appeals and quashed the criminal proceedings against the husband and his parents under Section 498-A IPC and the Dowry Prohibition Act. This ruling reaffirms the need for courts to carefully scrutinize allegations to prevent the misuse of legal provisions designed for the protection of women.

Cause Title: P.V. KRISHNABHAT vs. THE STATE OF KARNATAKA

Case No: Special Leave to Appeal (Crl.) No(s). 1754/2024

Date: January-15-2025

Bench: Justice Vikram Nath, Justice Sandeep Mehta

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