On 10th December, 2024, the Supreme Court reiterated its concern regarding the propensity to involve every member of the husband's family when domestic conflicts stem from marital discord, while dismissing a Section 498-A IPC (cruelty) case against a husband and the wife's in-laws. The Court further condemned the increasing trend of abusing Section 498-A IPC as a means of pursuing personal grievances against the husband and his family.

The bench, comprising Justice B.V. Nagarathna and Justice N. Kotiswar Singh, observed that Section 498-A of the IPC has been used as a legal tool by wives and their family members to settle disputes with their husbands and families without realising that the provision was intended to prevent women from being subjected to cruelty by the husband and his families and to ensure prompt action were taken by the State.

The case originated from the marriage of the Appellant no. 1 (husband) and Respondent no. 2 (wife), which was solemnised on March 8, 2015 and out of their wedlock, two minor children were born in 2016 and 2017.

The Respondent no. 2 filed a First Information Report (FIR) on February 1, 2022, alleging that her husband and his family harassed her for additional dowry. It was claimed that Rs. 10 lakhs, 10 tolas of gold, and other items were given as dowry at the time of marriage. Additional allegations included physical and mental harassment, abuse, and an illicit affair by the husband.

The Appellant approached the Telangana High Court to quash the FIR filed against him, which the High Court refused. Thus, aggrieved by the same, the husband and his family appealed to the Supreme Court.

On the bare perusal of the FIR, the bench found the allegations made by respondent No. 2 as vague and omnibus because they lacked specific details such as time, place and manner in which the alleged harassment occurred.

Further, while considering the records, the bench observed the Respondent-wife's own admission of leaving the marital home and assured reconciliation attempts, which failed and consequently led Appellant No. 1 to file a petition to dissolve their marriage.

While determining the involvement of Appellants Nos. 2-6 (family members of Appellant No. 1), the bench found no connection, as they resided separately and were included without substantial claims.

Resultantly, the bench deemed that the FIR filed was not a genuine complaint, but rather a retaliatory measure intended to settle scores with appellant No. 1 and his family members.

The Court condemned such a measure, stating that the provision was intended to protect wives who were abused in the marital home, mainly because of an illegal demand for any property or valuable security in the form of dowry. However, the complainant-wife had abused the provision as a counterblast to the petition for dissolution of marriage that the first appellant-husband had sought.

Ultimately, after due considerations, the bench held that , “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.”

Thus, the current case against the Appellants was quashed and accordingly the appeal was therefore granted.

Case Title: Dara Lakshmi Narayana & Other VERSES State Of Telangana & Another

Advocate for Petitioner(s): Mr. Shubham Kumar, Adv. Mr. Chand Qureshi, AOR

Advocate for Respondent(s): Ms. Devina Sehgal, AOR