Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | – 0 |
| Diary Number | 47072/2023 |
| Judge Name | HON’BLE MRS. JUSTICE B.V. NAGARATHNA |
| Concurring or Dissenting Judges | R. Mahadevan J. (concurring) |
| Precedent Value | Binding |
| Overrules / Affirms | Affirms existing precedent |
| Type of Law | Criminal law – criminal procedure & matrimonial offences |
| Questions of Law | Whether general/matrimonial discord and financial‐control allegations amount to “cruelty” under Section 498A IPC and Sections 3 & 4 DP Act, and whether such allegations bar quashing under Section 482 CrPC. |
| Ratio Decidendi | The Supreme Court held that allegations reflecting daily wear and tear of marriage, financial control without tangible harm, and non-specific taunts (e.g., keeping an excel sheet of expenses or demanding postpartum weight loss) do not fall within the statutory definition of “cruelty” under Section 498A IPC or dowry offences under Sections 3 and 4 DP Act. Vague, omnibus allegations motivated by malice or as a counterblast to matrimonial proceedings can be quashed under inherent powers of Section 482 CrPC. |
| Judgments Relied Upon |
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| Logic / Jurisprudence / Authorities Relied Upon |
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| Facts as Summarised by the Court | The parties married in December 2016 and lived in Michigan, USA where they had a child in April 2019; the wife returned to India in August 2019 amid discord; appellant husband sent a notice for restitution of conjugal rights in January 2022; on 27.01.2022 a FIR under Section 498A IPC and Sections 3 & 4 DP Act was registered alleging vague dowry demands, forced expense-tracking, financial control and postpartum neglect; the Telangana High Court refused quash in April 2023. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts |
| Persuasive For | Other High Courts and the Supreme Court |
| Follows |
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What’s New / What Lawyers Should Note
- The Court clarified that everyday marital disagreements and non-specific financial control do not constitute “cruelty” under Section 498A IPC.
- Dowry‐related criminal charges (Sections 3 & 4 DP Act) cannot rest on vague or omnibus allegations without particulars of demand or delivery.
- Section 482 CrPC may be invoked to quash mala fide FIRs filed as counter-blasts in matrimonial disputes.
- Mental harassment must be shown to cause grave injury or coercion; excel-sheet accounting or postpartum taunts alone fail the test.
- Invoking 498A IPC against family members requires specific allegations of active involvement.
Summary of Legal Reasoning
- The Court examined the FIR and complaint, noting allegations of dowry demands, financial dominance, forced expense‐tracking and postpartum negligence.
- It interpreted “cruelty” under Section 498A IPC and penal provisions under Sections 3 & 4 DP Act, emphasizing the need for wilful conduct causing grave injury or coercion.
- Applying inherent powers under Section 482 CrPC and the tests in Bhajan Lal (1992 Supp (1) SCC 335), the Court held that general, non-specific allegations do not prima facie disclose offences.
- Relying on Dara Lakshmi Narayana (2025 3 SCC 735), it stressed that mere family-member inclusion without particularised conduct is an abuse of process.
- Finding mala fide counterblast and absence of quantifiable harm, the Court quashed the FIR and subsequent complaint proceedings.
Arguments by the Parties
Petitioner
- The FIR contains sweeping, unsubstantiated allegations amounting to daily wear and tear, not cruelty.
- It was filed in malice as a counterblast to a restitution-of-conjugal-rights notice.
- Co-accused family members have already been exonerated by High Court.
Complainant-Respondent No. 2
- Suffered actual atrocities: forced to maintain detailed expense logs, deprived of funds, neglected during and after pregnancy.
- Husband sent large sums to his family while denying her basic support.
- Faced constant dowry demands allegedly totaling ₹1 crore.
State (Respondent No. 1)
- Supported continuation of prosecution based on allegations of harassment and dowry demands.
Factual Background
The parties, both software engineers, married in December 2016 and relocated to Michigan, USA, where they had a son in April 2019. Matrimonial discord led the wife and child to return to India in August 2019. In January 2022, the husband sought restitution of conjugal rights, following which the wife filed a complaint alleging dowry harassment. A FIR under Section 498A IPC and Sections 3 & 4 DP Act was registered on 27.01.2022; the Telangana High Court refused quashing in April 2023, prompting the present appeal.
Statutory Analysis
- Section 498A IPC penalizes cruelty by husband or relatives—wilful conduct causing grave injury or coercion for unlawful demands.
- Section 3 DP Act punishes giving/taking/abetting dowry with at least five years’ imprisonment and fine.
- Section 4 DP Act penalizes demanding dowry with 6 months to 2 years’ imprisonment and fine.
- The Court held that absent specific, tangible acts fulfilling these elements, criminal prosecution is an abuse of process.
Alert Indicators
- ✔ Precedent Followed – The decision reaffirms Bhajan Lal and Dara Lakshmi Narayana guidelines on quashing and matrimonial cruelty.