The Bombay High Court quashed a First Information Report (FIR) against a man and his family, ruling that the "indiscriminate" use of Section 498A of the Indian Penal Code (IPC) by "highly educated" women complainants undermines the provision's purpose. From the Nagpur bench, single-judge Justice Pravin Patil highlighted a "disturbing pattern" where educated women file Section 498A FIRs against husbands and their relatives purely to settle personal scores.

Court's Key Observations: 

"This Court cannot remain oblivious to the disturbing pattern that has emerged in recent times, wherein matrimonial prosecutions are frequently initiated as a pressure tactic during subsistence of marital disputes and negotiations," stated Justice Patil.

 The judge pointed out that educated complainants often target not just the spouse but the husband's entire family including elderly parents, married sisters, and distant relatives living separately without specific or credible claims of their involvement.

"Such indiscriminate invocation of the criminal process trivialises the very object of Section 498-A IPC and erodes its moral and legal force, thereby doing disservice to genuine victims of cruelty," observed the court.

Justice Patil warned that allowing such cases to continue without strong evidence results in prolonged harassment, social stigma, and lasting damage to innocent people."The inherent powers of this Court are intended to act as a constitutional safety, required to be invoked to avoid the innocent persons from prosecuting in the criminal offence," the judge added.

While praising the "laudable" intent behind Section 498A, he expressed concern: "However, it is a matter of serious concern that large number of cases continue to be filed under Section 498-A of IPC alleging harassment of married women. Most of such complaints are filed in the heat of the moment over trivial issues. Many of such complaints are not bona fide.

"Complainants often fail to foresee the fallout, resulting in undue distress for both accused and accuser.”

"This Court has to exercise incidental power to quash even a non-compoundable case of private nature, if continuing the proceedings is found to be oppressive," the judge remarked.

Case Background:

The couple got married on June 15, 2020, amid the COVID-19 surge. The husband holds BTech and MBA degrees; the wife has a BE in Electronics. They moved to a rented apartment in Pune, but disagreements soon soured their relationship. After parental intervention and mediation through  a matchmaker,  the issues  were temporarily resolved, only to resurface.

 The husband filed a non-cognizable report (NCR) with the  Pune Police, alleging that  his wife had  verbally abused him and might file a false case against him. He then moved out and began staying at  a friend's place. The wife relocated to Washim with her in-laws, announced that she was  pregnant, and was advised by the husband to terminate the pregnancy while he initiated divorce proceedings.

 Subsequent family meetings resulted in  a mutual divorce agreement. Initially, it was decided that  Rs 30 lakhs along with certain items would be paid, but  the amount was  later increased  to Rs 35 lakhs. The agreement also included a consensual termination of the pregnancy.

 However, two months later, on July 1, 2024, the wife  filed a Section 498A FIR against the husband, his parents, his married sister, and her husband, who was  residing  in a separate district. 

Judicial Analysis and Ruling:

Reviewing WhatsApp chats, Justice Patil found: "Perusal of this conversation clearly established the fact that wife has used unparliamentary language in her messages to the husband. So also these messages clarify the fact that their relations were so strained that there was no other way than to separate from each other. As such, the husband has taken the decision and filed the divorce proceeding against the wife." 

The court observed  that the wife’s cruelty claims under Section 498A were unclear, broadly made, and lacked specific details.

"In my opinion, in the present case the Applicants have placed on record sound, reasonable and indubitable material which is relevant and impeccable allegations levelled against them. The material, which is collected and produced before this Court, in my opinion, is sufficient to reject and overruled the assertions contained in the complaint," held the court.

Accordingly, the FIR was quashed.

Case Title: Vaibhav Gopaldas Mundada vs State of Maharashtra 

(Criminal Application 1349 of 2024)