498A | Generalised and Sweeping Accusations Unsupported by Concrete Evidence Cannot Form the Basis for Criminal Prosecution:  Supreme Court

“You Can’t Criminalise Kinship”, - In a decisive blow against the misuse of criminal law in matrimonial disputes, the Supreme Court of India quashed the dowry harassment case filed against three distant in-laws of the husband. The Court held that allegations without specificity or substantiation cannot be allowed to proceed to trial.

Justice Prashant Kumar Mishra, writing for the Bench along with Justice Ahsanuddin Amanullah, remarked pointedly: “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.”

The Court reinforced its consistent disapproval of what it termed the “growing trend of involving the relatives of the husband” in 498A IPC cases, especially when such relatives are geographically distant and functionally uninvolved in the marriage.

The case arose from the marriage of the de-facto complainant with one Challa Poornananda Reddy solemnized on 24 May 2014 at Guntur. Marital discord followed soon, with the wife leaving the matrimonial home repeatedly and the husband eventually initiating proceedings for restitution of conjugal rights. A compromise was attempted, but failed.

When the husband moved for dissolution of marriage in June 2016, the complainant filed a second FIR on 13 February 2016, this time implicating six persons — including A4 to A6, who were distant relatives of the husband residing in Hyderabad.

The appellants included the husband’s sister-in-law, her husband, and her father-in-law — all of whom denied any involvement in the matrimonial discord, citing physical and residential distance from the couple and absence of any direct participation in the dispute.

The Court was categorical that the allegations lacked specificity. The complainant alleged that the appellants “used to instigate the husband and his parents,” demanded ₹5 lakh, and taunted that “had the husband married elsewhere, he could have received ₹10 crores dowry.” These, the Court held, were generic assertions lacking time, place, or proof.

“There is no specific date as to when the present appellants visited Guntur and joined accused nos. 1 to 3 in demanding dowry from the de-facto complainant.”

The Court emphasized that not only were the appellants non-residents of the matrimonial home, but also there was no evidence of physical cruelty or direct involvement in the marital strain. It reiterated a consistent line of authority: “Such generalised and sweeping accusations unsupported by concrete evidence or particularised allegations cannot form the basis for criminal prosecution.”

The Court referred to its earlier judgment in Geeta Mehrotra v. State of Uttar Pradesh (2012) 10 SCC 741, where it held that implicating extended family members without specific allegations is improper and unjust.

It also relied on its recent judgment in Dara Lakshmi Narayana v. State of Telangana (2024), where the Court observed: “Appellant Nos. 2 to 6 have no connection to the matter at hand and have been dragged into the web of crime without any rhyme or reason.”

The Bench, in that case, had cautioned against the tendency to file FIRs “to settle personal scores and grudges,” especially against relatives who live in different cities and have little or no involvement.

Justice Mishra, in a sharp rebuke of the misuse of criminal law for personal vengeance, underscored that courts must act as gatekeepers, preventing frivolous litigation that burdens not only the accused but also the judicial system.

He observed: “There has been a growing tendency to misuse provisions like Section 498A IPC as a tool for unleashing personal vendetta against the husband and his family.”

“Sometimes, recourse is taken to invoke Section 498A IPC… in order to seek compliance with the unreasonable demands of a wife.”

“If not scrutinized, such vague and generalised allegations will lead to misuse of legal processes and an encouragement for use of arm-twisting tactics.”

The Court concluded that the FIR and the subsequent case against the appellants were part of a retaliatory legal strategy, with no real substance or cause for prosecution.

Quashing Criminal Case No. 359 of 2016, the Supreme Court allowed the appeal and held that forcing distant in-laws — who have no proximate role — to face criminal trial amounts to an abuse of judicial process.

Justice Amanullah, concurring, summed it up: “In the present case also, it is an admitted position that the appellants are residing at Hyderabad whereas the de-facto complainant stayed in her marital house at Guntur… There is omnibus allegation… which deserves to be quashed.”

With this ruling, the Supreme Court once again reiterated the constitutional imperative of personal liberty and the necessity of specificity in criminal allegations, especially in matrimonial matters.

Date of Decision: April 23, 2025