Misuse of Section 498A IPC and Dowry Prohibition Act in Matrimonial Disputes

Dara Lakshmi Narayana v. State of Telangana (2024 INSC 953)

In Dara Lakshmi Narayana v. State of Telangana,1 the Supreme Court of India once again confronted the recurring problem of misuse of Section 498A of the Indian Penal Code, 1860 (“IPC”) and the Dowry Prohibition Act, 1961. The judgment, delivered on 10 December 2024 by a Bench of B.V. Nagarathna and Nongmeikapam Kotiswar Singh, JJ., quashed criminal proceedings against the appellants, holding that the allegations were vague, omnibus, and motivated by personal vendetta.

The decision underscores judicial concern over the “over-implication” of in-laws in matrimonial disputes and reiterates that Section 482 of the Code of Criminal Procedure, 1973 (“Cr.P.C.”) must be used to prevent abuse of process in cases where allegations are general and unsupported.

Factual Background

The marriage of appellant No. 1 (husband) and respondent No. 2 (wife) was solemnized in March 2015. Appellant Nos. 2 and 3 were the husband’s parents, while appellant Nos. 4–6 were his sisters. Respondent No. 2 alleged that at the time of marriage, her family paid ₹10 lakhs in cash, ten tolas of gold, and household articles as dowry, in addition to ₹5 lakhs as marriage expenses.

After marriage, the couple resided in Jollarpeta, Tamil Nadu, where appellant No. 1 worked in the Southern Railways. Two children were born out of the wedlock in 2016 and 2017. The wife alleged that her husband harassed her physically and mentally, abused her in drunken states, suspected her fidelity, and had an illicit relationship with another woman. Against the in-laws (appellant Nos. 2–6), she alleged instigation for additional dowry.

In February 2022, she lodged FIR No. 82/2022 at Neredmet Police Station, Rachakonda, under Section 498A IPC and Sections 3 and 4 of the Dowry Prohibition Act.

Procedural History

The appellants sought quashing of the FIR before the Telangana High Court under Section 482 Cr.P.C. The High Court, while granting protection against arrest in line with Arnesh Kumar v. State of Bihar, refused to quash the proceedings. A charge-sheet was filed in June 2022 against appellant Nos. 1–6, but charges were dropped against accused No. 7 (brother-in-law). The appellants thereafter approached the Supreme Court.

Submissions of the Parties

A. Appellants’ Submissions

1. No demand for dowry was ever made by them; instead, the wife frequently deserted the matrimonial home without intimation.

2. A letter dated 11 November 2021, written by the wife to the Deputy Superintendent of Police, admitted that she had left home voluntarily due to quarrels and interactions with one Govindan, and acknowledged that her husband was taking good care of her.

3. A legal notice seeking mutual divorce was issued by the husband on 13 December 2021; the present FIR, lodged shortly thereafter, was filed as a counterblast.

4. Appellant Nos. 2–6 resided in different cities and had no connection with the matrimonial household, yet were falsely implicated without specific allegations.

B. Respondent-State’s Submissions

The State contended that:

1. A prima facie case of cruelty and dowry demand was disclosed in the FIR.

2. The wife’s father had corroborated the dowry transaction in his statement.

3. The High Court was correct in refusing to quash proceedings at the threshold.

Court’s Analysis

A. Applicability of Bhajan Lal Guidelines

The Court reaffirmed the parameters laid down in State of Haryana v. Bhajan Lal, particularly Category (1) (where allegations even if taken at face value do not constitute an offence) and Category (7) (where proceedings are maliciously instituted to wreak vengeance).

B. Vague and Omnibus Allegations

The FIR, the Court observed, lacked details regarding time, place, and nature of the alleged harassment. The allegations against appellant Nos. 2–6 were stereotypical and without specificity. Courts, it emphasized, must guard against the tendency to rope in all family members of the husband in matrimonial disputes, especially when they reside separately.4

C. Retaliatory Nature of Complaint

The Court placed weight on the sequence of events: the wife had left the matrimonial home in October 2021, admitted her fault in November 2021, and was served with a divorce notice in December 2021. The FIR filed in February 2022 was therefore viewed as retaliatory and not a bona fide grievance.

D. Judicial Warnings Against Misuse of Section 498A

The Court cited G.V. Rao v. L.H.V. Prasad,5 cautioning against indiscriminate matrimonial litigation that unnecessarily implicates elders who might otherwise reconcile the parties. Further, in Preeti Gupta v. State of Jharkhand,6 it had been held that vague allegations against relatives living in different places must be scrutinized with great circumspection.

Decision

Allowing the appeal, the Supreme Court quashed FIR No. 82/2022, the subsequent charge-sheet, and pending trial against appellant Nos. 1–6. It held that the High Court erred in declining to exercise its inherent jurisdiction under Section 482 Cr.P.C. when the record clearly indicated abuse of process.

Significance

This ruling fortifies judicial recognition of the misuse of Section 498A IPC as a tool of retribution in matrimonial discord. Its key contributions are:

1. Reinforcement of Bhajan Lal categories: Where allegations are vague or motivated, quashing is justified.

2. Protection of extended family: Mere mention of relatives’ names in complaints, without specific acts, cannot justify prosecution.

3. Recognition of retaliatory complaints: Timing and context of FIRs are relevant in assessing mala fides.

While reaffirming that genuine instances of cruelty must be prosecuted, the judgment emphasizes judicial vigilance against harassment of innocent relatives and abuse of criminal law in matrimonial conflicts.

References

1. Dara Lakshmi Narayana v. State of Telangana, 2024 INSC 953 (Dec. 10, 2024).

2. Arnesh Kumar v. State of Bihar, (2014) 8 SCC 273.

3. State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335.

4. See also Kahkashan Kausar v. State of Bihar, (2022) 6 SCC 599
   (emphasizing caution against indiscriminate prosecution of in-laws).

5. G.V. Rao v. L.H.V. Prasad, (2000) 3 SCC 693.

6. Preeti Gupta v. State of Jharkhand, (2010) 7 SCC 667.