'Cruel Misuse' Of S.498A IPC: Supreme Court Acquits Husband In 26 Yrs Old Cruelty And Dowry Case Citing Lack Of Credible Evidence

The Supreme Court has cautioned against the 'cruel misuse' of Section 498A IPC (cruelty cases) against husband and in-laws by the wife and her relatives, without concrete evidence.

“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 prosecutions, and casts serious suspicion on the viability of the version of a Complainant.”, the court said.

The bench comprising Justices BV Nagarathna and SC Sharma made these observations while acquitting the Appellant-husband of the charges under Section 498A IPC and Section 4 of the Dowry Prohibition Act for allegedly subjecting his wife to cruelty and dowry demands. The FIR was lodged back in the year 1999.

The wife alleged that the appellant subjected her to physical and mental cruelty, including kicking, punching, forced consumption of narcotics, and humiliation. She also claimed that he made dowry demands amounting to ₹2 lakhs and caused a miscarriage through assault, although no medical evidence was provided to support this claim. Notably, the couple cohabited for only 12 days after their marriage.

The judgment authored by Justice Sharma noted that the allegations levelled against the Appellant were vague, omnibus, and lacked specifics (no dates, times, or independent witnesses).

Relying on the recent judgment in Dara Lakshmi Narayana & Ors. v. State of Telangana & Anr., the Court reiterated its concern over the increasing trend of filing cruelty cases against husbands and their family members without credible evidence. It observed that such misuse not only undermines the prosecution's case but also casts serious doubt on the credibility of the complainant-wife's allegations.

“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, insofar as aged parents, distant relatives, married sisters living separately, are arrayed as accused, in matrimonial matters. This growing tendency to append every relative of the husband, casts serious doubt on the veracity of the allegations made by the Complainant wife or her family members, and vitiates the very objective of a protective legislation.”

“We cannot ignore the missing specifics in a criminal complaint, which is the premise of invoking criminal machinery of the State. Be that as it may, we are informed that the marriage of the Appellant has already been dissolved and the divorce decree has attained finality, hence any further prosecution of the Appellant will only tantamount to an abuse of process of law.”, the court added.

Accordingly, the appeal was allowed.

Case Title: RAJESH CHADDHA VERSUS STATE OF UTTAR PRADESH

Citation : 2025 LiveLaw (SC) 563

Click here to read/download the judgment

Appearance:

For Petitioner(s) Ms. Preetika Dwivedi, AOR

For Respondent(s) Mr. Shaurya Sahay, AOR Mr. Aditya Kumar, Adv. Ms. Ruchil Raj, Adv.