498A is a “Cruel Misuse” Supreme Court Judgement 13/5/2025



Title: Supreme Court Acquits Husband in Dowry Harassment Case After 20 Years Due to Lack of Evidence and Vague Allegations

Summary:

In Rajesh Chaddha v. State of Uttar Pradesh [2025 INSC 671], the Supreme Court of India set aside the conviction of the appellant-husband under Section 498A of the IPC and Section 4 of the Dowry Prohibition Act, 1961, citing lack of evidence and vague allegations. The Court held that general and unsubstantiated claims without specific details could not form the basis of a criminal conviction. The trial had dragged on for over two decades, and the apex court observed misuse of dowry laws in matrimonial disputes, particularly against distant and unrelated family members. The judgment reiterates the need for specificity and credible material in cases invoking Section 498A IPC.

In a significant judgment, the Supreme Court of India in Rajesh Chaddha v. State of Uttar Pradesh [2025 INSC 671], acquitted the appellant-husband who was convicted by the trial court in 2004 under Section 498A of the Indian Penal Code and Section 4 of the Dowry Prohibition Act, 1961. The conviction had been upheld by both the Sessions Court and the High Court, but the apex court found the prosecution case lacking in essential particulars and material evidence.


Background:

  • The appellant, Rajesh Chaddha, married the complainant, Mala Chaddha, on 12 February 1997.
  • The complainant alleged mental and physical torture for not bringing enough dowry.
  • She claimed to have been ousted multiple times from the matrimonial home and suffered a miscarriage due to physical assault.
  • The FIR was filed on 20 December 1999, nearly a year after the appellant had filed a divorce petition on 6 February 1999.
  • The complainant cohabited with the appellant for only about one year.

The Trial Court acquitted the appellant of charges under Sections 323, 506 IPC due to lack of medical evidence and failure to prove hurt or miscarriage. However, it convicted him under Section 498A IPC and Section 4 of the Dowry Prohibition Act based solely on the testimonies of the complainant and her father.

The Sessions Court and the High Court later upheld this conviction. The appellant approached the Supreme Court after nearly two decades of litigation.

Supreme Court’s Observations:

  1. Lack of Specific Allegations:
  • The Court noted that the allegations were vague, general, and lacked specific instances, dates, or locations.
  • The complainant failed to submit any medical evidence to support her claim of physical assault or miscarriage.
  1. Insufficient Evidence:
  • The only evidence presented was the statements of the complainant and her father.
  • No corroborative medical or documentary proof was provided.
  1. Delay and Background of FIR:
  • The Court highlighted that the FIR was lodged after the husband filed for divorce, indicating possible retaliatory motives.
  1. Misuse of Dowry Laws:
  • The Court expressed concern over the misuse of Section 498A IPC and dowry laws.
  • It emphasized the increasing trend of implicating all relatives of the husband, including those not living with the couple, in dowry harassment cases.
  1. Responsibility of Courts:
  • Courts must scrutinize such cases carefully to prevent misuse of the legal process.
  • Vague and omnibus allegations without supporting evidence cannot justify conviction.

Conclusion and Verdict:

The Supreme Court allowed the appeal and acquitted the appellant of all charges under Section 498A IPC and Section 4 of the Dowry Prohibition Act. The Court held that the continuation of criminal proceedings would be an abuse of the legal process, especially since the divorce between the parties had already attained finality.

The Court concluded that the justice delivery system must ensure that protective laws are not used as tools of harassment in matrimonial conflicts.


Legal Significance:

This judgment reinforces the need for courts to distinguish between genuine cases of cruelty and those driven by malice. It is a crucial precedent emphasizing that criminal convictions cannot rest on unsubstantiated or emotionally charged allegations without concrete evidence.

The verdict is a reminder that the criminal justice system should not become a weapon in personal disputes and that due process and fair trial rights must be upheld, even in sensitive matrimonial matters.

3 Thoughts to “498A is a “Cruel Misuse” Supreme Court Judgement 13/5/2025”

  1. Mayank Agarwal

    Very sad affairs in our country without any proof and interested witnesses and just by the testimony of wife and her family members,husband and his family suffered so much mentally, physically and monetarily and also subject to prison for 3 long years and that too not only by trial and sessions court but also by high court.Who will bring back the sufferings of last 20 years his whole life for destroyed.wife and her family should be severely punished for destroying the innocent persons life and also judges should also be reprimanded but sadly I don’t think wife side will face any repercussions for this.His and his families whole life and reputation got destroyed.Sadly speaking this is no justice what will he do of this acquittal after more than 20 years as the irreparable damage has been done already as no one can bring these 20 years back.

  2. Ramakant Deora Chandrapur Maharashtra

    It is unfortunate that the police officers who prepare the FIR under Section 498 A do not scrutinize the matter regarding date time and place of cruelty caused by husband.They should first verify the incidents of cruelty and only thereafter register the FIR under Section 498A.
    Ramakant Deora Chandrapur Maharashtra

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