A) ABSTRACT / HEADNOTE

The Supreme Court in Rajesh Chaddha v. State of Uttar Pradesh [2025] 6 S.C.R. 382, dealt with the conviction of the appellant under Section 498A, Indian Penal Code, 1860 and Section 4, Dowry Prohibition Act, 1961, which had been upheld by the Allahabad High Court in its revisionary jurisdiction. The Court critically examined whether vague and omnibus allegations without specific instances of cruelty or demand of dowry could sustain a conviction under these penal provisions. It observed that the prosecution evidence was primarily based on the complainant-wife and her father’s depositions, devoid of medical corroboration, time, place, or date-specific incidents. Allegations of miscarriage and physical assault were unsupported by any documentary evidence, thereby weakening the prosecution’s case. The Court highlighted the increasing misuse of Section 498A and provisions of the Dowry Prohibition Act, cautioning against the malicious roping in of family members in matrimonial disputes. The FIR lodged by the complainant was also viewed as retaliatory, given it was filed subsequent to the husband’s divorce petition. Ultimately, the Court set aside the conviction, acquitting the appellant of all charges, reiterating that protective legislations cannot be allowed to become tools of harassment.

Keywords: Section 498A IPC; Section 4 Dowry Prohibition Act, 1961; cruelty; miscarriage; false implication; revisionary jurisdiction; misuse of 498A; omnibus allegations; matrimonial disputes; malicious prosecution.

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The instant appeal arose from the Allahabad High Court’s order affirming the conviction of the appellant under Section 498A IPC and Section 4 Dowry Prohibition Act, 1961. The genesis of the dispute lies in matrimonial discord between the appellant, Rajesh Chaddha, and his wife Mala Chaddha, who alleged persistent dowry demands and physical and mental cruelty. The prosecution’s case centered on the wife’s claims that her in-laws, including the appellant, subjected her to harassment, humiliation, and physical assault for insufficient dowry, culminating in miscarriage and ouster from the matrimonial home.

The Trial Court had acquitted the appellant of Section 323 r/w 34 IPC and Section 506 IPC but convicted him under Section 498A IPC and Section 4 DP Act, 1961. The Additional Sessions Judge upheld the conviction, and the High Court dismissed the revision petition. The appellant approached the Supreme Court challenging the legality and correctness of the conviction, asserting that the allegations were vague, unsubstantiated, and retaliatory in nature as they followed his divorce petition.

The broader legal background involves the judicial scrutiny of Section 498A IPC and dowry provisions, which, while intended as protective mechanisms for women, have been subjected to criticism due to misuse and indiscriminate implication of husband’s relatives. Precedents such as Bhagwan Jagannath Markad v. State of Maharashtra (2016) 10 SCC 537 and Arun Vyas v. Anita Vyas (1999) 4 SCC 690 recognized the gravity of cruelty and dowry-related harassment but emphasized the necessity of cogent evidence. Recently, in Dara Lakshmi Narayana v. State of Telangana (2025) 3 SCC 735, the Supreme Court warned against blanket roping in of in-laws in matrimonial disputes without specific allegations.

Against this jurisprudential backdrop, the Court in the present case had to reconcile the balance between safeguarding women from domestic cruelty and preventing abuse of criminal law as an instrument of vengeance in broken marriages.

D) FACTS OF THE CASE

The appellant, Rajesh Chaddha, married Mala Chaddha on 12 February 1997. The complainant claimed she was compelled to resign from her teaching job on the advice of her husband. Her family allegedly spent over Rs. 5 lakhs on the wedding. The appellant and his family purportedly expressed dissatisfaction with the dowry and subjected her to physical and mental harassment.

She alleged being forced to consume narcotic-laced milk, compelled to attend parties against her will, and subjected to humiliation if she resisted. She further claimed that her in-laws, in conspiracy with her husband, attempted to confine her in a “safe house,” intending to kill her. On 23 September 1998, the complainant alleged she was beaten in front of her father when a demand of Rs. 2 lakhs was unmet. She further claimed miscarriage due to being pushed out of the matrimonial home on 10 February 1998.

The FIR dated 20 December 1999 was lodged after alleged reconciliation efforts failed. During trial, the complainant and her father testified as PW-1 and PW-2. They reiterated claims of dowry demand and harassment but could not substantiate physical assault or miscarriage with medical evidence. No injury reports or medical certificates were produced.

The Trial Court acquitted the accused under Sections 323/34 IPC and Section 506 IPC, citing lack of corroboration, but convicted the appellant under Section 498A IPC and Section 4 DP Act, 1961, sentencing him to two years rigorous imprisonment with fine. The Sessions Court and subsequently the High Court upheld the conviction. The appellant’s plea before the Supreme Court emphasized the retaliatory nature of the complaint, lack of specifics in allegations, absence of corroborative evidence, and the fact that a divorce decree had already attained finality.

E) LEGAL ISSUES RAISED

i. Whether the conviction of the appellant under Section 498A IPC and Section 4 Dowry Prohibition Act, 1961 was sustainable in the absence of specific, date-bound, and corroborated allegations of cruelty and dowry demand?

ii. Whether the High Court, while exercising revisionary jurisdiction, erred in upholding the conviction without adequate scrutiny of evidence and in the absence of counsel for the appellant?

iii. Whether omnibus and vague allegations without material particulars amount to cruelty within the meaning of Section 498A IPC?

iv. Whether filing of the FIR after the appellant’s divorce petition raises suspicion about the bona fides of the prosecution?

v. Whether continued prosecution in such circumstances amounts to an abuse of process of law?

F) PETITIONER / APPELLANT’S ARGUMENTS

i. The counsel for the appellant argued that the allegations were vague and bereft of material particulars. The FIR lacked date, time, and event-specific instances of cruelty or dowry demand, making it unsustainable under criminal law.

ii. The prosecution relied solely on the testimonies of the complainant and her father without independent corroboration. No medical records substantiated allegations of physical assault or miscarriage, which should have been indispensable for conviction under Sections 323 and 498A IPC.

iii. The appellant contended that the FIR was retaliatory, lodged after he filed for divorce under Section 13, Hindu Marriage Act, 1955. The divorce decree had attained finality, thereby weakening the complainant’s allegations.

iv. It was further argued that the High Court passed the order in absence of counsel for the appellant. The Court should have appointed an amicus curiae rather than pronouncing an order adverse to the appellant without representation.

v. The conviction under Section 498A IPC and Section 4 DP Act, 1961 was based on conjecture and suspicion rather than concrete proof, which is impermissible in criminal jurisprudence that requires proof beyond reasonable doubt.

G) RESPONDENT’S ARGUMENTS

i. The State argued that cruelty under Section 498A IPC can be established on the basis of testimony of close relatives of the complainant. The depositions of the complainant and her father sufficiently established harassment and dowry demand.

ii. Reliance was placed on precedents like Bhagwan Jagannath Markad v. State of Maharashtra (2016) 10 SCC 537, Arun Vyas v. Anita Vyas (1999) 4 SCC 690, and Surendran v. State of Kerala (2022) 15 SCC 273, to argue that mental harassment, taunts, and repeated dowry demands fall within the ambit of cruelty.

iii. It was contended that insistence on documentary or medical corroboration in cases of matrimonial cruelty would defeat the protective purpose of Section 498A IPC and Dowry Prohibition Act, 1961, since such acts often occur within the four walls of the matrimonial home.

iv. The High Court had rightly upheld the conviction, finding no perversity in the concurrent findings of the Trial Court and Sessions Court.

H) RELATED LEGAL PROVISIONS

i. Section 498A, Indian Penal Code, 1860 – Husband or relative of husband subjecting woman to cruelty.

ii. Sections 3 and 4, Dowry Prohibition Act, 1961 – Penalty for giving/taking dowry; penalty for demanding dowry.

iii. Section 323, IPC – Punishment for voluntarily causing hurt.

iv. Section 506, IPC – Criminal intimidation.

v. Section 34, IPC – Acts done by several persons in furtherance of common intention.

vi. Section 164, CrPC, 1973 – Recording of statements by Magistrate.

vii. Section 13, Hindu Marriage Act, 1955 – Divorce grounds.

I) JUDGEMENT

The Supreme Court allowed the appeal, setting aside the High Court’s order and acquitting the appellant. The Court emphasized that the allegations were vague, general, and unsupported by cogent evidence. The complainant failed to specify time, date, and particulars of alleged harassment. No medical records substantiated claims of miscarriage or physical assault. The FIR’s timing, following the appellant’s divorce petition, undermined its genuineness.

The Court observed that the Trial Court erred in convicting the appellant under Section 498A IPC and Section 4 DP Act, 1961 on mere possibility rather than proof beyond reasonable doubt. The High Court, in revisionary jurisdiction, failed to scrutinize the correctness of findings and overlooked the lack of incriminatory material. The Court condemned the growing misuse of Section 498A where relatives of the husband are indiscriminately implicated.

The Court held that missing specifics in a criminal complaint cannot invoke penal provisions meant to protect women. While acknowledging the possibility of emotional trauma suffered by the complainant, the Court ruled that such subjective claims without corroborative evidence cannot ground a criminal conviction.

Accordingly, the conviction was set aside, and the appellant acquitted of all charges.

a. RATIO DECIDENDI

The ratio of the case lies in the principle that conviction under Section 498A IPC and Section 4 DP Act, 1961 requires clear, specific, and corroborated allegations. Vague, omnibus, and unsubstantiated claims cannot meet the threshold of criminal liability. Proof beyond reasonable doubt is indispensable in criminal law, and protective legislations cannot be used as tools for harassment.

The Court reiterated that “cruelty” under Section 498A IPC refers to willful conduct likely to cause grave injury to life, limb, or health, including mental harassment, but such allegations must be supported by material particulars. Similarly, dowry demand under Sections 3 and 4 DP Act, 1961 must be proved with concrete evidence.

The Court emphasized judicial responsibility in scrutinizing vague allegations to prevent misuse of protective statutes and avoid malicious criminal prosecution in matrimonial disputes.

b. OBITER DICTA

The Court expressed concern about the rampant misuse of Section 498A IPC and dowry provisions. It observed that indiscriminate implication of aged parents, distant relatives, and sisters living separately, without specific allegations, has become a common abuse of law. Courts must exercise caution to prevent unnecessary harassment of innocent family members.

The Court acknowledged the emotional distress of complainant-wives but held that subjective feelings without corroboration cannot be the basis of criminal prosecution. FIRs filed as counter-blasts to divorce petitions reflect malicious intent and abuse of process.

It also observed that missing specifics in a complaint—such as time, place, and date of alleged incidents—undermine its credibility. Protective laws must not degenerate into instruments of vendetta.

c. GUIDELINES

i. Allegations under Section 498A IPC and Dowry Prohibition Act, 1961 must be specific, with dates, times, and particulars of incidents.

ii. Courts should insist on corroborative evidence—medical records, independent testimony, or material documents—where allegations involve physical assault, miscarriage, or serious injury.

iii. FIRs filed subsequent to matrimonial litigations like divorce petitions must be scrutinized for mala fides.

iv. Revisionary jurisdiction requires careful examination of lower court orders; High Courts must not mechanically uphold convictions without analyzing evidence.

v. Courts must prevent misuse of protective statutes by nipping in the bud cases where relatives are indiscriminately implicated without specific allegations.

vi. Emotional or mental harassment must be substantiated by demonstrable conduct rather than vague claims.

J) CONCLUSION & COMMENTS

The judgment represents a crucial reaffirmation of the principle that criminal law cannot be based on suspicion, conjecture, or vague allegations. The Supreme Court struck a balance between protecting women from domestic cruelty and preventing misuse of protective statutes for vendetta in matrimonial disputes.

The acquittal was necessitated by lack of corroborative evidence and the retaliatory nature of the complaint. The Court’s insistence on specificity, corroboration, and scrutiny of mala fide complaints strengthens jurisprudence against misuse of Section 498A IPC and Dowry Prohibition Act, 1961. The decision reinforces that criminal law demands proof beyond reasonable doubt, and its misuse undermines both justice and the legitimacy of protective legislations.

This ruling echoes prior jurisprudence like Dara Lakshmi Narayana v. State of Telangana (2025) 3 SCC 735, which deprecated malicious roping in of relatives. It provides judicial guidelines to curb indiscriminate prosecutions while safeguarding genuine cases of cruelty.

Ultimately, the judgment underscores that while matrimonial disputes can involve emotional trauma, courts must differentiate between genuine cases of cruelty and weaponization of criminal law. This ensures justice both to victims of domestic violence and to accused individuals wrongfully implicated.

K) REFERENCES

Important Cases Referred

i. Dara Lakshmi Narayana & Ors. v. State of Telangana & Anr., (2025) 3 SCC 735
ii. Bhagwan Jagannath Markad v. State of Maharashtra, (2016) 10 SCC 537
iii. Arun Vyas & Anr. v. Anita Vyas, (1999) 4 SCC 690
iv. Surendran v. State of Kerala, (2022) 15 SCC 273

Important Statutes Referred

i. Indian Penal Code, 1860 – Sections 498A, 323, 506, 34
ii. Dowry Prohibition Act, 1961 – Sections 3, 4
iii. Code of Criminal Procedure, 1973 – Section 164
iv. Hindu Marriage Act, 1955 – Section 13