Supreme Court Quashes Criminal Proceedings U/S 498A IPC: Absence of Specific Allegations and Evidence Against Appellants

In a significant ruling, the Supreme Court of India quashed the criminal proceedings against Mahalakshmi and others in a marital cruelty and dowry demands case, citing the “absence of specific allegations and evidence against appellants.” The bench comprising Justices Sanjiv Khanna and S.V.N. Bhatti highlighted the need for concrete evidence in cases involving marital disputes.

The appellants, Mahalakshmi, Maharani T.S., Ranjanavadhan, and Archana, were implicated in a case filed by Rekha Bhaskaran, under Sections 498A and 506 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act, 1961. The Supreme Court, in its judgment, observed that the allegations against the appellants were vague and lacked specific details that constitute cruelty under section 498A of the IPC.

Justice Khanna, while delivering the judgment, stated, “In the absence of any material evidence of interference and involvement in the marital life of the complainant, may not be sufficient to implicate the person as having committed cruelty under section 498A of the IPC.” This observation underlines the court’s stance on the necessity of substantive evidence in cases alleging marital cruelty.

The court also pointed out that appellant no. 1, Mahalakshmi, was not residing in India at the time of the alleged incidents, and the other appellants were living separately from the complainant’s marital home. This further weakened the prosecution’s case, leading to the quashing of the criminal proceedings.

The judgment also referenced several precedents, emphasizing the need for specific allegations and evidence in marital cruelty cases, such as Kahkashan Kausar @ Sonam and others v. State of Bihar and others, (2022) 6 SCC 599, and others.

While the proceedings against the appellants have been quashed, the court clarified that if any new material evidence comes to light during the recording of evidence, it would be open for the trial court to take action under Section 319 of the Code of Criminal Procedure.

Date of Decision: 30^th November 2023

MAHALAKSHMI & ORS. VS THE STATE OF KARNATAKA & ANR.