Supreme Court Acquits Husband in Dowry Harassment Case: Raises Concern Over Misuse of Section 498A IPC

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Summary of the Judgment:

Case: Rajesh Chaddha v. State of Uttar Pradesh
Judgment Date: 13 May 2025
Bench: Justice B. V. Nagarathna and Justice Satish Chandra Sharma
Type: Criminal Appeal from SLP (Crl.) Nos. 2353-54 of 2019

Background:

Rajesh Chaddha and Mala Chaddha were married in February 1997. Their cohabitation lasted for only 12 days. In December 1999, Mala filed a complaint under Sections 498A, 323, 506 IPC, and Sections 3 & 4 of the Dowry Prohibition Act, alleging mental and physical abuse, dowry demands, and a miscarriage due to assault.

Lower Court Findings:

  • Trial Court: Convicted Rajesh under Section 498A IPC and Section 4 of the Dowry Prohibition Act, awarding 2 years and 1 year imprisonment respectively. It acquitted him of charges under Sections 323 and 506 IPC due to lack of medical evidence.

  • Sessions Court & High Court: Upheld the conviction. The High Court, in its 2018 order, found no legal error or perversity in the trial court's findings.

Supreme Court's Observations:

1. Lack of Independent Evidence:

  • Only the complainant (wife) and her father testified; no other independent witness was examined.

  • No medical records were submitted to support allegations of injury or miscarriage.

2. Vague and General Allegations:

  • Allegations lacked specific dates, times, or instances of cruelty.

  • Statements were deemed ambiguous and insufficient to establish guilt under criminal law.

3. Marriage Already Dissolved:

  • Divorce between the parties was finalized and not challenged by the wife.

4. Caution Against Misuse of Law:

  • The Court noted the growing misuse of Section 498A IPC and dowry laws by adding every relative of the husband without specific allegations.

  • Cited the Dara Lakshmi Narayana case, warning against "mechanical" inclusion of distant relatives in criminal complaints.

Key Excerpt from the Judgment:

“The term ‘cruelty’ cannot be presumed merely on emotional claims. Specific instances with evidence are required. Otherwise, criminal proceedings become a tool of harassment rather than justice.”

Final Verdict:

  • The Supreme Court set aside the conviction under Section 498A IPC and Section 4 of the Dowry Prohibition Act.

  • Rajesh Chaddha was acquitted of all charges.

Conclusion:

This judgment stands as a milestone in protecting individuals from wrongful criminal prosecution in matrimonial disputes. While upholding the sanctity of protective laws like Section 498A IPC, the Supreme Court has emphasized the importance of evidence and judicial restraint to prevent misuse.

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