Section 498A IPC Not A Weapon To Settle Grudges Against In-Laws Without Specific Evidence: Supreme Court Acquits Father-In-Law

"Legislature enacted Section 498A as a safeguard for women in their marital homes, not as a weapon against all members of the family indiscriminately", Supreme Court, in a significant ruling, held that Section 498A of the Indian Penal Code (IPC) must not be misused to rope in all family members in the absence of specific roles or evidence.

A bench of Justice Aravind Kumar and Justice N.V. Anjaria observed that the provision, intended as a shield for women, cannot be transformed into a tool for settling personal scores against in-laws. The Court subsequently set aside the conviction of a father-in-law, noting that his implication appeared to be an "extension of roping in the husband."

The case involved a woman who died of 55% burn injuries within nine months of her marriage in 2001. While the Trial Court had convicted the husband and his parents for murder (Section 302 IPC) and cruelty (Section 498A IPC), the High Court later acquitted them of the murder charge but upheld the conviction under Section 498A. The matter reached the Supreme Court through cross-appeals filed by the father-in-law against his conviction, and by the State and the deceased's brother against the acquittal under Section 302 IPC.

The primary questions before the court were whether the conviction under Section 498A IPC could be sustained based on contradictory dying declarations and improved witness testimonies. The court was also called upon to determine if the acquittal under Section 302 IPC by the High Court required interference.

Contradictory Dying Declarations Cast Shadow On Prosecution Case

The Court scrutinized two conflicting dying declarations of the deceased. In the first statement (Ex. P-22), she alleged that her in-laws set her ablaze due to dowry demands. However, in the second declaration (Ex. P-30) recorded a day later, she stated she had set herself on fire following a quarrel. The bench noted that the Executive Magistrate (PW-18) admitted in cross-examination that individuals present with the deceased at the hospital had tutored her to depose in a particular manner during the first recording.

Court Explains Principles For Relying On Dying Declarations

Referring to the landmark precedent in Khushal Rao v. State of Bombay, the Court emphasized that while a dying declaration can form the sole basis of conviction, it must be tested for reliability. The bench observed that for a declaration to be beyond reproach, it must not be the result of tutoring by interested parties. In this case, the variation in the two declarations and the evidence of tutoring rendered the first statement unreliable, making the second version of suicide more believable.

Improvements In Witness Testimonies Deemed An Afterthought

The Court expressed concern over the testimonies of the deceased’s family members (PW-1, PW-2, PW-3, and PW-5). Although they claimed before the Trial Court that the deceased was harassed for a Maruti car, these allegations were entirely absent from their initial statements recorded under Section 161 of the CrPC. The bench noted that these improvements appeared across all witnesses with a "jarring accuracy," indicating a coordinated afterthought rather than a genuine lapse of memory.

Non-Disclosure Of Dowry Demands To Police Undermines Credibility

The bench remarked that a fact as traumatic as a dowry demand leading to death would naturally be narrated to the police at the first instance. The Court found it "unsafe" to rely on the contradictory statements of interested witnesses when no independent witness, including neighbours, supported the dowry demand theory. It noted that the family's attempt to blame the police for non-recording of these facts was a "legal gimmick" to strengthen a weak case.

Section 498A Cannot Be Used To Target Family Indiscriminately

The Court highlighted the disturbing trend of roping in all family members in matrimonial disputes. It observed that no direct evidence was produced to implicate the father-in-law for mental cruelty or direct involvement in torture. "It seems that the father-in-law was roped in the present matter by an extension of roping the husband of the deceased, as is the case in certain S. 498A matters," the bench noted.

Circumstantial Evidence Must Exclude Every Hypothesis Of Innocence

Applying the "Panchsheel" principles from Sharad Birdhichand Sarda v. State of Maharashtra, the Court held that the chain of evidence was incomplete. The Court reiterated that where two inferences are possible, the one favouring the accused must be accepted. Since the prosecution failed to prove the demand for dowry or the act of murder beyond reasonable doubt, the circumstances did not point exclusively to the guilt of the accused persons.

Acquittal Of Father-In-Law And Dismissal Of Murder Appeals

The Court concluded that the evidence was insufficient to establish the charge under Section 498A against the father-in-law, Narendra Singh. It also found no reason to interfere with the High Court's decision to acquit the accused persons of the murder charge under Section 302 IPC, as the medical evidence and conflicting declarations did not conclusively establish a homicidal death.

In conclusion, the Supreme Court allowed the appeal filed by the father-in-law, setting aside his conviction and sentence. The appeals filed by the State of Madhya Pradesh and the brother of the deceased challenging the acquittal under Section 302 IPC were dismissed.

Date of Decision: 30 April 2026