Court Highlights Misuse of Section 498A IPC, Emphasizes Caution in Proceeding Against Distant Relatives
In a significant ruling, the Bombay High Court has quashed an FIR and subsequent charge-sheet against the father-in-law and brother-in-law of a woman involved in a matrimonial dispute. The court underscored the need for caution while proceeding against distant relatives based on omnibus allegations under Section 498A of the Indian Penal Code (IPC).
The judgment was passed in the case of Amrik Singh Saini v. State of Maharashtra, where the petitioners, Amrik Singh and his son Amit, were implicated by the complainant, the wife of Rumit Saini. The complainant alleged that her in-laws and husband induced her to hand over her gold ornaments and subjected her to physical and mental cruelty. However, the court found that the allegations against the petitioners did not constitute 'cruelty' as defined under Section 498A of the IPC.
The bench, comprising Justices Bharati Dangre and Shyam C. Chandak, noted that the misuse of Section 498A IPC has been a concern expressed by the Supreme Court in previous judgments. The court referred to landmark cases, including Kahkashan Kausar @ Sonam v. The State of Bihar and K. Subba Rao v. The State of Telangana, which highlighted the trend of implicating relatives in matrimonial disputes without prima facie evidence.
The court observed that the complainant's allegations were primarily motivated by personal disputes with her husband, and the inclusion of his relatives seemed to be an act of vendetta. The judges emphasized that unfounded criminal charges and prolonged prosecution could cause irreparable damage, including mental trauma, financial loss, and reputation harm.
In their order, the judges quashed the FIR No. 533 of 2024 and the related charge-sheet, stating that continuing with the proceedings would amount to an abuse of the process of law. The ruling serves as a reminder to lower courts to exercise restraint and ensure that relatives are not unnecessarily dragged into legal battles without substantive evidence.
The judgment is expected to have far-reaching implications, reinforcing the need to protect individuals from frivolous litigation while ensuring that genuine cases of domestic abuse are addressed with due diligence.
Bottom Line:
Misuse of Section 498A of IPC - Relatives of husband implicated in matrimonial disputes without prima facie case - Courts must exercise caution in proceeding against relatives based on omnibus allegations.
Statutory provision(s): Section 498A of the IPC, Sections 85, 351(2), 115(2), 3(5), and 352 of Bharatiya Nyaya Sanhita, 2023, Section 528 of Bharatiya Nagarik Suraksha Sanhita, 2023, Article 226 of the Constitution of India.
Amrik Singh Saini v. State of Maharashtra, (Bombay)(DB) : Law Finder Doc Id # 2833280
