Supreme Court Quashes 498A Conviction, Holds Evidence Insufficient and Warns Against Misuse in Matrimonial Disputes

A bench of Justices B.V. Nagarathna and Satish Chandra Sharma heard the criminal appeal arising out of SLP (Crl.) Nos. 2353-2354 of 2019, challenging the Allahabad High Court’s order upholding the conviction of the appellant for offences under Section 498A IPC and Section 4 of the Dowry Prohibition Act, 1961. The appeal arose from proceedings in Case Crime No. 60/1999 registered at Women Police Station, Lucknow, and impugned both the High Court’s judgment dated 14.11.2018 and its refusal to recall that order.

The Court allowed the appeals and set aside the conviction, holding that the prosecution had not produced sufficient material to establish cruelty or dowry demand beyond reasonable doubt. The Court observed that allegations were largely “vague, omnibus and bereft of any material particulars” and that, apart from the complainant and her father, there was no independent corroboration or medical evidence to substantiate claims of hurt or miscarriage. The Court, in its reasoning, observed: “Upon carefully considering the record, we find that apart from the statements of PW‑1 and PW‑2, there is no evidence to substantiate the allegations of harassment and acts of cruelty within the scope of Section 498A of IPC, and Section 4 of the D.P. Act, 1961. For this reason, we find merit in the submission of the learned Counsel for the Appellant, and are of the considered view that there is no material on record to establish the allegations of hurt or miscarriage, and of hurt and criminal intimidation in terms of Section 323 r/w 34 and Section 506 IPC respectively.” The Court further warned that the term “cruelty” could be subject to misuse and cited that “a mere reference to the names of family members in a criminal case arising out of a matrimonial dispute, without specific allegations indicating their active involvement should be nipped in the bud.”

Background

The complainant, Mala Chaddha, alleged repeated mental and physical cruelty and unlawful dowry demands after her marriage to Rajesh Chaddha on 12.02.1997. The FIR dated 20.12.1999 alleged violence, forced consumption of narcotic/alcoholic substances, demands of Rs. 2 lakhs, snatching of salary and that an ouster resulted in a miscarriage. The complainant and her father (PW‑1 and PW‑2) testified; no medical records or independent witnesses were produced to verify injuries or miscarriage. The Chief Judicial Magistrate convicted the appellant under Section 498A IPC and Section 4 DP Act and sentenced him to imprisonment and fines, while acquitting co‑accused for Section 323 r/w 34 and Section 506 IPC for lack of corroboration. The Additional Sessions Judge and thereafter the Allahabad High Court upheld the conviction.

On appeal, the Supreme Court examined statutory thresholds for cruelty under Section 498A IPC and the demand offences under the Dowry Prohibition Act and found that the prosecution’s case lacked particulars of time, place or manner and that crucial medical evidence was missing. The Court noted that the FIR was registered after the husband had filed a divorce petition and observed that the allegations could not be sustained on a “cursory or plausible view” alone. Applying settled principles that criminal provisions should not be loosely invoked in matrimonial disputes and referring to precedent, the Court concluded that further prosecution would amount to an abuse of process, particularly where the marriage had been dissolved and the decree had attained finality. The appeals were allowed and the appellant was acquitted of all charges; pending applications were disposed of.

Case No.: 2025 INSC 671 Case Title: Rajesh Chaddha v. State of Uttar Pradesh Appearances: For the Petitioner(s): Counsel not indicated in the judgment For the Respondent(s): Counsel not indicated in the judgment