Sometimes marrying the love of your life is not a guarantee for a successful marriage and may even turn out to be a nightmare. A Brahmin boy had to go through a testing time, when his lover of schedule caste (SC) class left him after two years of marriage and filed dowry, 498A and SC/ST Atrocity cases which included multiple allegations.
Based on her allegations police filed chargesheet in 2019, against her husband and her in-laws imposing: 498A, 504, 506 of Indian Penal Code, Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act, 1989, and Dowry Prohibition Act, 1961. The High Court in 2023 provided some relief to husband by quashing the SC/ST Act, 504 and 506 cases. However, it refused to quash the criminal proceedings concerning Section 498-A and Dowry Prohibition Act, 1961. Hence they approached the Supreme Court for justice.
While the above mentioned sections were criminal proceedings, simultaneously family court proceedings were ongoing for divorce case.
Read below to find how much the family court judgement helped prove that the wife filed false criminal cases for personal vendetta and how did the husband win this case and got relief for his parents also.
Mysore Family Court finds wife treated husband with cruelty instead of the other way around
Wife alleged that her husband was a ‘sex maniac’ and ‘drug addict’. She also claimed that her father had paid several amounts to her husband for rent, his foreign travels, etc. upon demands made by him. Further, she also alleged that her in-laws would also harass her and make caste-based remarks whenever they used to visit them in Bangalore, where they resided.
Contrary to the claim of the wife about him being a sex maniac and drug addict, the family court dismissed such allegations.On August 19, 2023 the additional principal judge of Family Court at Mysuru observed the following in its order:
- It has been held that the complainant (wife) herein has made false allegations regarding the gifting of a car during marriage and extending of financial help by her father for the husband’s foreign trips.
- It has also been observed that from the evidence put before, it is conclusive that the allegations of the husband being a drug addict and a sex maniac have been made only to take unreasonable advantage in the divorce as well as the criminal proceedings.
- The Family Court has concluded that the wife has made several bald and baseless allegations against the husband and thereby treated the husband with cruelty, and thus the Family Court has passed the decree of divorce on the grounds of cruelty.
Supreme Court cautions against usage of Section 498A case for personal vendetta
The Supreme Court came down heavily on misuse of section 498A and said in its order dated January 15, 2025:
- “Criminal law should not be used as a tool for harassment or vendetta. The allegations in a criminal complaint must be scrutinized with care to ensure that they disclose a prima facie case before subjecting individuals to the rigors of a criminal trial.”
- “The cases involving allegations under Section 498-A of the IPC and the DP Act (Dowry Protection) often require a careful and cautious approach to prevent misuse of the law. While the provisions are intended to protect women from cruelty and dowry harassment, they should not be used to settle personal scores or pursue ulterior motives.”
- “In the present case, the allegations against the appellants were devoid of merit, manifestly frivolous and fail to disclose a prima facie case. The continuation of criminal proceedings in such circumstances would amount to an abuse of the process of law and result in a miscarriage of justice.”
Nikhil Varshney, Partner, Cyril Amarchand Mangaldas, says, “This judgment reinforces that criminal law ought not to be weaponized for settling personal vendettas and urges Courts to exercise careful scrutiny to prevent vexatious litigation under protective legislation.”
How did the Supreme Court find out about the wife filing false 498A case for personal vendetta?
The Supreme Court broke down the criminal cases into two segments- one filed against the in-laws and another against the husband.
- The criminal case against In-laws (husband’s parents) lacked specific details: “After a thorough consideration of the submissions and the materials placed on record, the allegations against the father-in-law and mother-in-law are indeed general and lacked specificity. The complainant has not provided any concrete details of dowry demands or acts of cruelty attributable to them. The admitted fact of their separate residence further weakens the complainant’s case against them. In the absence of prima facie evidence to establish their involvement in the alleged offenses, the proceedings against the father-in-law and mother-in-law cannot be sustained.”
- The criminal case against the husband lacks evidence: “Regarding the husband, it is evident that the allegations against him are similarly vague and unsubstantiated. The complainant (wife) has made generalized accusations without furnishing specific instances of misconduct. No specific allegations and neither any material have come on record to show a prima facie commission of the alleged offences of cruelty and dowry demand. The couple had a love marriage and experienced a blissful relationship during the initial years of their marriage, as is admitted on record. This, coupled with the lack of material evidence to support the allegations, leads to the conclusion that no prima facie case of cruelty or dowry demand is made out against the husband as well. Criminal proceedings cannot be permitted to continue in the absence of sufficient evidence to prima facie establish the commission of an offense.”
Supreme Court: Mysore Family Court’s observations helped prove wife’s ulterior motive for filing 498A case
The Supreme Court placed special emphasis on the observations of Mysore Family Court, since the Additional Principal Judge of that court could manage to find the wife’s true intentions.
The Supreme Court said:
- As is evident from the record, the marriage between the parties has been dissolved, with categorical findings regarding cruelty meted out by the complainant against the appellant-husband.
- The allegations made in the criminal complaint, regarding dowry demand, cruelty, and harassment have all been held to be baseless, false and frivolous. Though these are separate proceedings, but findings regarding the truth and veracity of such serious allegations, as have been made by the complainant herein, become relevant in order to do justice and avoid misuse of the criminal justice system.
- The Family Court has made categorical findings to hold that the allegations are false and nothing has been produced to or prove any merit in the allegations. Even in the criminal proceedings impugned before us, nothing has come on record to show commission of these alleged acts, even on a prima facie analysis.
- Once it has been held that there is no merit or truthfulness to the allegations made, then criminal proceedings on the very same allegations cannot be allowed to continue and propagate misuse of the criminal justice system.
“Accordingly, the appeals are allowed and the criminal proceedings under Section 498-A of the IPC and Sections 3 and 4 of the DP Act (Dowry Protection) against all the appellants are quashed,” as per the order of Supreme Court.
What are some key legal takeaways from this judgement?
ET Wealth Online has asked various experts about what might be some key legal takeaways from this judgement. Here’s what they said:
Nidhi Mohan Parashar, AOR Supreme Court of India and Partner, Vedya Partners: The judgement is an example of how the Supreme Court of India is ensuring that abuse of criminal process is curtailed and is coming down heavily against wives using the state machinery to settle personal scores. The approach of the Supreme Court has been seen to be more balanced as compared to the high courts on the issue of quashing of FIRs relating to matrimonial offences.
Shiv Sapra, Partner, Kochhar & Co: This judgment reiterates what the Courts have been forewarning against for almost two decades. Ever since the case of Sushil Kumar Sharma vs. Union of India, the apprehension of frivolous and vexatious complaints has been a cause of concern. Even in the recent case of Dara Lakshmi Narayana vs. State of Telangana the Supreme Court reprimanded the misuse of the legal provisions.
The Judgment in question serves as a reminder of the oft settled law and should act as a deterrent and caution to those who seek to abuse as a tool, what is otherwise a remedy.
Ankit Rajgarhia, Principal Associate, Karanjawala & Co: The judgment reinforces that Section 498-A IPC should not be used as a tool for harassment or vendetta. It emphasizes that criminal proceedings must be based on specific, clear, and prima facie evidence rather than vague or general allegations. The judgment acknowledges that findings in civil proceedings (such as the Family Court granting divorce on cruelty grounds) can be considered in criminal cases when the allegations overlap. If a court has already determined that the allegations are false, it adds weight to quashing criminal proceedings on the same grounds.
Courts must carefully examine cases filed under Section 498-A IPC and the Dowry Prohibition Act to ensure they are not misused for settling personal scores. It aligns with past Supreme Court rulings, such as Rajesh Sharma & Ors. v. State of U.P. (2017) and Arnesh Kumar v. State of Bihar (2014), which cautioned against the misuse of these provisions.
Nikhil Varshney, Partner, Cyril Amarchand Mangaldas: The Supreme Court has held that general allegations sans specific instances or material evidence cannot satisfy the prima facie threshold for sustaining prosecution. The Supreme Court has been quite clear in recognising that laws designed to protect, can sometimes be misused, creating an atmosphere of mistrust in the system.
Prachi Dubey, Advocate, Delhi High Court: The judgment sets a precedent that criminal proceedings under Section 498A IPC and the Dowry Prohibition Act should not continue in the absence of prima facie evidence. It reinforces that vague, general, or baseless allegations—especially in matrimonial disputes—should not be used to harass individuals or misuse the criminal justice system. Courts must carefully scrutinize such cases to prevent injustice.
Alay Razvi, Managing Partner, Accord Juris: The judgment reinforces the judiciary’s cautious approach in dealing with cases of alleged cruelty and dowry harassment, ensuring that these legal provisions are not weaponized for personal or vindictive reasons. Let’s understand why Section 498 A was introduced. It was to protect married women from cruelty by their husbands and in-laws. However, over a period of time, false cases have been filed to harass the husband , his family members and distant relatives. It is important to note that Section 498A should not be a tool of revenge in matrimonial disputes. A thorough enquiry should be conducted before registering such a complaint. In the event if a false case is identified , necessary proceedings should be initiated for filing of false complaint.
This judgment emphasises on preventing misuse of section 498A, safeguarding against arbitrary prosecution of husband’s extended family, Judicial Scrutiny in Dowry-Related Allegations, Strengthening the Fair Use of Legal Provisions and Call for Legislative & Procedural Reforms.
Shashank Agarwal, Advocate, Delhi High Court: Marriages are ultimately a bond between two people. Marriages start with a lifelong promise to be together till the end of their lives. However, the bonds of marriages also break, mostly, on a sour note. The laws under section 498A of the IPC, the Dowry Prohibition Act, the Domestic Violence Act, are intended to protect women against cruelty by husbands. However, their misuse has been overgrown by the wives to settle scores as well as by their family members as a means of recovery of monies spent by them for the wedding and in good times of the couple. This judgement will set a precedent for all such women to not use such laws to their benefit by placing wrongful and baseless allegations.
