The Supreme Court recently acquitted a man in a 26-year-old dowry and cruelty case, while raising concerns about the misuse of Section 498A (cruelty to married woman) of the Indian Penal Code (IPC) and the Dowry Prohibition Act, 1961, in matrimonial disputes (Rajesh Chaddha vs. State of Uttar Pradesh).
The Bench of Justices BV Nagarathna and Satish Chandra Sharma overturned the man's conviction on finding that the allegations against him were vague, omnibus, and lacking in specifics.
It also lamented that Section 498A, IPC, which punishes cruelty to married women, is itself being subjected to 'cruel misuse' in matrimonial disputes without any 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 Court underscored that allegations under Section 498A, IPC must be substantiated with concrete evidence, including specific dates, times, and instances, rather than being based on broad, unsupported claims.
"... the allegations cannot be ambiguous or made in thin air ... 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," the Court added in its judgement.
The Court proceeded to flag concerns about the growing misuse of dowry laws, as complainants often implicate multiple family members without specific accusations, leading to malicious prosecution.
"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," it said.
The case concerned a first information report (FIR) registered in 1999 on a complaint by the accused man's wife, alleging mental and physical cruelty, and dowry harassment. The complainant-wife also accused him of causing a miscarriage due to physical assault.
The trial court convicted the husband under Section 498A, IPC and Section 4 of the Dowry Prohibition Act, sentencing him to two years and one year of rigorous imprisonment, respectively. The conviction was upheld by the Allahabad High Court in 2018. He then filed an appeal before the Supreme Court.
The Supreme Court acquitted the accused man on May 13. 2025 since complainant’s allegations lacked material particulars and independent corroboration.
Among other factors, the complainant failed to provide medical evidence to substantiate the miscarriage claim or specific instances of physical assault.
The Court observed that merely emotional or mental distress, without concrete evidence, is not enough to convict the accused under Section 498A, IPC. It emphasised that criminal law requires proof beyond reasonable doubt and that vague, uncorroborated accusations undermine the integrity of the protective legislation.
Referring to its recent judgment in Dara Lakshmi Narayana & Ors. v. State of Telangana & Anr., the Court also reiterated that sweeping allegations against extended family members, without citing any specific acts of cruelty, cannot form the basis of criminal prosecution.
It cautioned against the growing tendency of implicating multiple family members in matrimonial disputes without credible evidence, stressing that such misuse undermines the intended protective nature of Section 498A, IPC.
The Court also noted that the complainant and the appellant had cohabited for only 12 days after their marriage in 1997, and that the FIR was filed after the husband initiated divorce proceedings, further casting doubt on the genuineness of the allegations.
The Bench concluded that the evidence presented by the prosecution failed to meet the legal threshold required for conviction, leading it to acquit the accused appellant of all charges.
