Dowry Cases Must Not Be Misused for Personal Agendas: Supreme Court
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In a significant ruling, the Supreme Court (SC) has underlined the importance of a cautious approach in cases involving dowry harassment allegations, urging that the law be safeguarded from misuse. While these legal provisions are designed to protect women from cruelty and dowry-related abuse, the apex court warned that they should not be exploited for personal vendettas or ulterior motives.
A bench consisting of Justices Vikram Nath and Sandeep Mehta allowed a criminal appeal filed by a man and his parents, seeking to quash a case registered under various sections of the Indian Penal Code (IPC), the Dowry Prohibition Act, 1961, and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The complaint, which was filed by the man’s wife, initially accused them of cruelty, harassment, and dowry demands.
The Karnataka High Court had partially allowed their plea to quash the charges but refused to dismiss the proceedings under Section 498A of the IPC and sections of the Dowry Prohibition Act. After reviewing the appeal, the Supreme Court found the allegations to be without merit, frivolous, and lacking prima facie evidence.
“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,” the bench noted. The court emphasized, “Criminal law should not be used as a tool for harassment or vendetta. The allegations in a criminal complaint must be scrutinized carefully to ensure that they disclose a prima facie case before subjecting individuals to the rigors of a criminal trial.”
The case dates back to February 10, 2019, when the wife filed a complaint alleging cruelty and harassment. She claimed that at the time of their marriage, several gifts, including a Swift car, gold jewelry, and a wedding expenditure of Rs 45 lakh, were provided. She also accused her husband of addiction to alcohol and drugs and claimed her in-laws subjected her to mental harassment and caste-based remarks when they visited her in Bengaluru.
Following the filing of the charge sheet, the appellants appealed to the Karnataka High Court, which noted that the allegations warranted further examination in the trial court. However, it observed that the accusations against the father-in-law and mother-in-law were vague and lacking in detail, though it chose not to quash the proceedings against them.
Representing the appellants before the Supreme Court, their counsel argued that the case was baseless and an abuse of legal process, pointing out that the man’s parents lived separately, which made their involvement unlikely. The counsel further stated that the accusations were generalized and lacked specifics of misconduct or unlawful demands.
For the husband, the lawyer argued that the allegations were vague and unsubstantiated, asserting that the couple had a harmonious relationship for the first two years, casting doubt on the claims of cruelty and harassment. The counsel also suggested that the complaint was a reaction to the breakdown of the marriage and that the continuation of the criminal proceedings would cause irreparable harm to the reputation of the appellants.
Additionally, the Family Court in Mysuru had granted the husband’s divorce petition on the grounds of cruelty on August 19, 2023. The court found that the claims regarding the car, trips, and other accusations were false, ruling that the allegations made by the complainant were intended to gain an unfair advantage.
In its final ruling, the Supreme Court agreed with the Family Court’s findings, noting that the allegations made by the complainant were vague and lacked merit. “Although these are separate proceedings, the findings regarding the truth and veracity of such serious allegations become relevant in order to do justice and avoid misuse of the criminal justice system,” the court stated.
The top court ultimately quashed the criminal proceedings, highlighting that the allegations were “manifestly frivolous” and failed to establish a prima facie case. “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,” the bench concluded.
