SC Quashes 498A Case: Vague Allegations Cannot Sustain Criminal Trial

The Supreme Court’s decision in Dara Lakshmi Narayana v. State of Telangana (2024) provides yet another reminder of the delicate balance courts must strike in matrimonial prosecutions under Section 498A IPC and the Dowry Prohibition Act.

The appellants husband and in-laws had sought quashing of FIR No.82 of 2022 lodged by the wife alleging harassment, dowry demands, and cruelty. The High Court, while shielding them from arrest, refused to quash proceedings, leading to this appeal.

What stands out in the judgment is the Court’s dissection of the FIR: the allegations were vague, omnibus, and lacked specific details of time, place, or manner. The record also revealed contradictions.

The wife had previously admitted in writing to leaving the matrimonial home after a quarrel linked to her own conduct and had acknowledged that her husband had taken care of her. Later, when served with a notice for mutual divorce, she filed the FIR.

Against this backdrop, the Supreme Court found the complaint retaliatory rather than genuine.

Equally important was the Court’s caution on the misuse of Section 498A. While reaffirming its purpose as a shield against real cruelty and dowry harassment, the Bench reiterated that indiscriminate implication of the husband’s entire family without specific allegations is an abuse of process.

The Court noted how family members residing in different cities had been unnecessarily dragged into litigation a pattern seen repeatedly in such disputes.

Relying on Bhajan Lal principles, the Court held that the case fell within the category of proceedings instituted with mala fides to wreak personal vengeance.

The prosecution was quashed in its entirety, protecting not just the husband but also the in-laws, with the Court underscoring that vague allegations cannot sustain criminal trials.

This ruling thus fits into the broader judicial trend: courts remain alive to genuine cases of cruelty but are equally vigilant against weaponisation of dowry laws in matrimonial discord. The message is clear—criminal law cannot be used as a tool of retaliation in broken marriages, and specificity of allegations remains the touchstone for prosecution to proceed.