The court held that where the prosecution case under Section 498-A IPC is riddled with glaring discrepancies, unexplained delays, and unsubstantiated allegations, conviction cannot be sustained. This judgment upholds and applies existing Supreme Court guidance on the need for clear, credible evidence in matrimonial cruelty cases, reaffirming the importance of strict evidentiary scrutiny for all subordinate courts in West Bengal.
Summary
| Category | Data |
|---|---|
| Case Name | CRA/643/2015 of GOURANGA MAITY Vs STATE OF WEST BENGAL |
| CNR | WBCHCA0515862015 |
| Date of Registration | 29-09-2015 |
| Decision Date | 27-10-2025 |
| Disposal Nature | ALLOWED |
| Judgment Author | HON’BLE JUSTICE CHAITALI CHATTERJEE DAS |
| Court | Calcutta High Court |
| Bench | Single Judge |
| Precedent Value | Binding on subordinate courts in West Bengal; persuasive for other jurisdictions |
| Overrules / Affirms | Affirms Supreme Court standards for evidence assessment under Section 498-A IPC |
| Type of Law | Criminal Law – Matrimonial Offences (Section 498-A IPC) |
| Questions of Law | Whether conviction under Section 498-A IPC can be sustained when serious inconsistencies, unexplained delays, and lack of corroboration exist in the evidence? |
| Ratio Decidendi | The conviction under Section 498-A IPC cannot be upheld where the prosecution’s case is marred by material inconsistencies and unexplained delay, and where the evidence of alleged cruelty and dowry demands is neither corroborated by contemporaneous record nor supported by credible testimony. The Court emphasized that discrepancies between written complaints and testimony, unexplained delay in filing complaints, and lack of reliable corroboration, especially when prosecution witnesses contradict themselves, render the prosecution case doubtful. Reliance on Supreme Court decisions highlighting the risk of misuse of Section 498-A further requires courts to scrutinize such allegations strictly. In the present case, the evidence was found unconvincing and charges were not proved beyond reasonable doubt, warranting acquittal. |
| Judgments Relied Upon | Dara Lakshmi Narayana and Others v. State of Telangana (2024 INSC 953); Achin Kumar Gupta v. State of Haryana (2024 INSC 369) |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Supreme Court observations on the necessity for clear, specific, and credible evidence under Section 498-A IPC to prevent misuse of the provision and unwarranted convictions; failure to prove charges beyond reasonable doubt mandates acquittal. |
| Facts as Summarised by the Court | The parties were married in 2008. After alleged dowry demands and claims of cruelty, multiple FIRs and complaints were filed by the complainant. The conviction of the husband under Section 498-A IPC was based on claims of assault, dowry demand, and cruelty. Evidence included contradictory and embellished versions, unexplained delay in complaint, and lack of corroboration. Other accused (in-laws) were acquitted. The High Court re-examined all evidence, noted inconsistencies, and set aside the conviction. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in West Bengal |
| Persuasive For | Other High Courts; Supreme Court (context-dependent) |
| Follows | Dara Lakshmi Narayana and Others v. State of Telangana (2024 INSC 953); Achin Kumar Gupta v. State of Haryana (2024 INSC 369) |
What’s New / What Lawyers Should Note
- Reaffirms that mere allegations of cruelty or dowry demand in the absence of credible, consistent, and corroborated evidence are insufficient for conviction under Section 498-A IPC.
- Highlights the judicial obligation to scrutinize matrimonial cruelty allegations strictly, especially where multiple contradictions and unexplained delays exist.
- Cites and applies current Supreme Court warnings regarding the potential misuse of Section 498-A as a tool for personal vendetta.
- Lawyers can rely on this judgment to challenge convictions where evidentiary inconsistencies, lack of timely complaint, and contradictions in key witness testimony occur.
Summary of Legal Reasoning
- The Court meticulously evaluated all prosecution and defense evidence, noting material contradictions between the written complaint and court testimony, such as changes in the alleged mode and severity of assault.
- Delay in lodging the complaint was brought up by the appellant and found by the Court to be unexplained by any credible evidence, further weakening the prosecution case.
- The medical evidence was inconclusive: the injury report date was inconsistent, and medical findings were not linked definitively to the alleged cruelty nor corroborated by witnesses or physical signs observed by the complainant’s father.
- The Court stressed settled law that convictions cannot be sustained on the basis of vague, generalized or embellished allegations lacking specific instances or credible corroboration.
- Reliance was placed on recent Supreme Court rulings (Dara Lakshmi Narayana and Achin Kumar Gupta) emphasizing the danger of misuse of Section 498-A and the importance of courts not acting on mere allegations not grounded in credible testimony.
- The prosecution evidence was found so inconsistent as to create reasonable doubt, necessitating acquittal.
Arguments by the Parties
Petitioner (Appellant/Husband)
- Asserted only 5-6 months of cohabitation and that the complainant habitually filed frivolous cases, all resulting in acquittal.
- Pointed to significant, unexplained delay between the alleged incident (15.02.2010) and the complaint’s filing (17.03.2010).
- Highlighted material inconsistencies and embellishments in the complainant’s evidence compared to her written complaint.
- Contended that other witnesses lacked direct knowledge of events; documentary evidence of ‘salishi’ attempts was never produced.
- Asserted prosecution failed to prove charges beyond reasonable doubt given contradictions and lack of corroboration.
Respondent (State/Prosecution)
- Argued conviction was justified based on witness corroboration of injury and evidence of ‘salishi’ meetings.
- Contended that minor inconsistencies or omissions are not fatal to the prosecution case where overall narrative and injury are proved.
- Asserted that prior acquittals in related cases do not, by themselves, negate the existence of cruelty in the present incident.
- Sought dismissal of the appeal.
Factual Background
The parties’ marriage was solemnized in March 2008. The complainant alleged that she was subjected to cruelty, dowry demands, and physical assault, leading to occasional departures from the matrimonial home. Several complaints and FIRs were filed, including the present one registered under Sections 498-A/325/307/34 IPC and sections of the Dowry Prohibition Act, after an incident allegedly occurring on 15.02.2010. She claimed severe assault and injury leading to her treatment at hospital. The trial court convicted only the husband under Section 498-A IPC, acquitting other accused. The High Court appeal focused on evidentiary inconsistencies, unexplained delay, and lack of corroboration.
Statutory Analysis
- Section 498-A IPC requires proof of cruelty or harassment by husband or his relatives to coerce a woman or her family to fulfill unlawful demands for property or valuable security.
- The Court discussed the interpretive approach guided by Supreme Court, stressing that evidence of cruelty must be specific, credible, and proceed from reliable facts—not generalized or unsubstantiated claims.
- Judicial scrutiny is heightened especially where delay in complaint lodging and evidence inconsistency are present.
- Sections under Dowry Prohibition Act and other IPC provisions (325, 307) were found not proved and not pressed in appeal.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinions are recorded in the judgment.
Procedural Innovations
No procedural innovations were set out in this judgment.
Alert Indicators
- ✔ Precedent Followed – Existing Supreme Court law affirmed.