The Supreme Court, in a ruling dated December 10, quashed a Section 498-A IPC (cruelty) case filed against a husband and his in-laws, reiterating concerns over the misuse of the provision in matrimonial disputes. The Court cautioned against the tendency of implicating all members of the husband's family in domestic disputes, especially when they arise due to matrimonial discord.
The bench, comprising Justices B.V. Nagarathna and N. Kotiswar Singh, expressed dismay over the growing trend of using Section 498-A IPC as a tool for personal vendettas. They noted that this provision, originally intended to protect women from cruelty and ensure swift state intervention, has increasingly been misused as a means to settle scores between estranged spouses. The Court highlighted that vague and generalized allegations in such cases could lead to the wrongful use of legal processes and exploitation of the law to exert pressure on the husband and his family.
“The inclusion of Section 498A of the IPC by way of an amendment was intended to curb cruelty inflicted on a woman by her husband and his family, ensuring swift intervention by the State. However, in recent years, as there have been a notable rise in matrimonial disputes across the country, accompanied by growing discord and tension within the institution of marriage, consequently, there has been a growing tendency to misuse provisions like Section 498A of the IPC as a tool for unleashing personal vendetta against the husband and his family by a wife. Making vague and generalised allegations during matrimonial conflicts, if not scrutinized, will lead to the misuse of legal processes and an encouragement for use of arm twisting tactics by a wife and/or her family. Sometimes, recourse is taken to invoke Section 498A of the IPC against the husband and his family in order to seek compliance with the unreasonable demands of a wife. Consequently, this Court has, time and again, cautioned against prosecuting the husband and his family in the absence of a clear prima facie case against them.”, the judgment authored by Justice Nagarathna said.
The case before the Court involved an appeal filed by the husband and his in-laws, challenging the Telangana High Court's decision not to quash a domestic cruelty case filed by the wife following the husband's petition for divorce. The Court criticized the wife’s action, noting that her complaint seemed to be a retaliatory response to the husband’s petition for dissolution of marriage, rather than a genuine case of cruelty.
While acknowledging that women facing cruelty should not be discouraged from filing complaints, the Court emphasized that provisions like Section 498-A should not be misused in situations like the one before them. The Court clarified that the intent behind Section 498-A was to protect women from cruelty related to unlawful dowry demands, and that the wife’s complaint in this case appeared to be an abusive countermeasure.
“We are not, for a moment, stating that any woman who has suffered cruelty in terms of what has been contemplated under Section 498A of the IPC should remain silent and forbear herself from making a complaint or initiating any criminal proceeding. That is not the intention of our aforesaid observations but we should not encourage a case like as in the present one, where as a counterblast to the petition for dissolution of marriage sought by the first appellant-husband of the second respondent herein, a complaint under Section 498A of the IPC is lodged by the latter. In fact, the insertion of the said provision is meant mainly for the protection of a woman who is subjected to cruelty in the matrimonial home primarily due to an unlawful demand for any property or valuable security in the form of dowry. However, sometimes it is misused as in the present case.”, the court observed.
The Court ultimately held that the Telangana High Court had made an error by not quashing the FIR against the appellants, and consequently, the case was dismissed. The appeal was allowed, and the pending case against the husband and his in-laws was quashed.
Case Title: DARA LAKSHMI NARAYANA & OTHERS VERSUS STATE OF TELANGANA & ANOTHER
Citation: 2024 INSC 953
Date: December-10-2024
Bench: Justice B.V. Nagarathna, Justice N. Kotiswar Singh
