In a recent judgment, the Supreme Court of India quashed criminal proceedings under Section 498A of the Indian Penal Code (IPC) against a father-in-law and mother-in-law. The Court emphasized the importance of courts being cautious while dealing with complaints in matrimonial disputes, especially when such complaints arise after several years of marriage or immediately following a divorce petition.
The case involved a couple married in 2005. The husband filed for divorce on May 15, 2019, and summons were served on July 17, 2019. Merely three days later, on July 20, 2019, the wife lodged a First Information Report (FIR) against her husband and his parents, alleging harassment and mental cruelty. The Gujarat High Court had earlier dismissed the petition to quash the FIR.
Challenging that decision, the appellants – the husband and his parents – approached the Supreme Court. The parents-in-law contended that the complaint was a counterblast to the divorce petition and amounted to misuse of the legal process. They also highlighted that the allegations lacked specific details and that they were living separately from the couple.
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After reviewing the FIR and related documents, the Supreme Court found no mention of dowry demands. The only claims against the in-laws were related to "taunts on trivial issues" and alleged withholding of the wife's salary. The wife admitted in the FIR that she had lived separately in rented homes and had been employed since 2008. The Court observed that no concrete or specific incidents of cruelty by the in-laws were detailed in the complaint.
“A few taunts here and there is a part of everyday life which, for the happiness of the family, are usually ignored,” the Court remarked.
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The Court further stated:
“In matrimonial disputes, particularly where allegations are made after many years of marriage and after one party has initiated divorce, courts must examine whether there is a possibility of malafide intent behind the complaint.”
As a result, the Supreme Court allowed the case to proceed only against the husband, as there were allegations of physical and mental abuse against him. The proceedings against the in-laws were quashed.
“The High Court adopted an extremely pedantic approach,” the bench noted, adding that High Courts should not take allegations at face value in such sensitive cases without examining their authenticity and timing.
Case Title: KAMAL & ORS. VERSUS STATE OF GUJARAT & ANR., SLP(Crl.) No.9167/2024
