A CURSORY VIEW INSUFFICIENT IN DETERMINING THE GUILT UNDER 498A AND DOWRY ACT: SUPREME COURT

The Apex Court on May 13, 2025, while deciding an appeal titled “Rajesh Chaddha v. State of Uttar Pradesh SLP (Crl) Nos. 2353-2354 of 2019”, arising out of a wife’s complaint against husband and in-laws alleging harassment on pretext of dowry, emphasized that such allegations cannot be vague and bereft of evidence. The bench of Justice Nagarathna and Justice Sharma highlighted that the allegations, required to attract the operation of 498A CrPC and provisions of Dowry Prohibition Act, need to have an authentic basis and consistency with the material on record, in order to especially disregard it as a tool to harass family members. The Supreme Court in this case, acquitted the Husband Rajesh Chaddha, who preferred an appeal against an Order passed by Allahabad High Court upholding his conviction by the lower court.

Background of the case

The dispute arose from a Complaint lodged by Wife, in 1999, against the Husband and her in-laws on the allegations of physical and mental abuse over the demands of Dowry. The complaint was lodged under Sections 498A, 323, 506 IPC and Sections 3, 4 of Dowry Prohibition Act, 1961 (D.P. Act). The Trial Court ruled out the play of Sections 323, 506 and 34 IPC due to lack of evidence but convicted only the Husband, under Section 498A and Section 4 of D.P. Act. The Appeal before the Additional Sessions Judge was dismissed and thereafter, the Revision Petition preferred before the Allahabad High Court was dismissed as well, with the remarks that there is no error of law. Subsequently, the Appellant Husband filed an application before the High Court seeking recall of the earlier Order and it was dismissed. Thereafter, this controversy reached the Supreme Court.

Points of Contention

The Supreme Court addressed the single issue of whether the Allahabad High Court was right in affirming the Trial Court’s order of conviction.

Legal Provisions Involved

• Section 498A of IPC – This provision empowers a woman to seek justice against the Husband or his relatives on grounds of ‘cruelty’. The provision defines cruelty as any form of physical or mental torture that threatens life or any other injury. As per the section, cruelty further includes harassment related to unlawful demands and dowry.
• Section 3 of D.P. Act – This provision penalises offering, accepting and abetting dowry.
• Section 4 of D.P. Act – This section penalises the demand for dowry. That can be coming from the parents or any other relative of the bride or bridegroom.

 

Analysis of the Apex Court

The Appellant’s arguments were broadly twofold. Firstly, during the pendency of the litigation, divorce has been granted, without any challenge from the wife. Secondly, the entire case was based upon the testimonies of the Complainant wife and her father and lacked any material evidence or any reference to specific dates or events to support the claims. It was further argued that the decision of High Court was passed in the absence of Appellant.

The State, while opposing, argued that the testimonies of the relatives of wife are material in the light of the decisions of the Supreme Court in cases “Bhagwan Jagannath Markad v. State of Maharashtra (2016) 10 SCC 537”, “Arun Vyas & Anr. v. Anita Vyas (1999) 4 SCC 690” , “Surendran v. State of Kerala (2022) 15 SCC 273”. Therefore, the testimony of the father was relevant is adjudicating upon the issue.

The Supreme Court while addressing the controversy remarked that in order to aptly attract the operation of Section 3 and 4 of D.P. Act, the allegations are unclear and vague. The Bench held that the present case deals with vague allegations not substantiated by evidence. There are incidents of abuse mentioned in the depositions and FIR but neither the specifics nor any medical document is there on record to substantiate them. It held that the use of “cruelty” cannot be done without providing specifics and that cannot be the ground for fuelling the State Machinery against someone. The Bench further remarked about the possibility of foul play in filing the FIR, the marital cohabitation lasted only for a year and the Husband filed for divorce. The Supreme Court reiterated its ruling in Dara Lakshmi Narayana & Ors. v. State of Telangana & Anr (2025) 3 SCC 735, where the Supreme Court discussed the growing misuse of the above mentioned provisions to involve the parents and relatives of a Husband and how it is a threat to the very principle behind a protective legislation.

Conclusion

The Supreme Court while dealing with this marital case that suffered with material irregularities and vague allegations, stressed upon the exponentially increasing misuse of the protections provided by the certain legislations, and the unjustified harassment of the relatives of Husband that are roped in over any kind of testimony against them. The Apex Court, with a view of precisely giving a sustainable solution, provided a more comprehensive interpretation of the term “Cruelty” and the quality of allegations surrounding it. This is a judgment that protects husbands from misuse of protective legislation.

 

Yash Hari Dixit

Associate

The Indian Lawyer and Allied Services

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