Groom Refuses To Cooperate With Wedding Reception Over Gold Demand; Supreme Court Upholds Conviction Under S.498A & Dowry Law

The Supreme Court upheld the conviction of a man under Section 498A of the Indian Penal Code and Section 4 of the Dowry Prohibition Act who refused to cooperate with the wedding reception function since the bride's family did not accept his demand for 100 sovereigns of gold as dowry.The case arose from a marriage which lasted only for three days.After the engagement ceremony held in 2006, the bridegroom and his family insisted that they would cooperate with the wedding reception only if 100 sovereigns of gold were given. The family of the appellant did not allow the bride's brother to perform the customary practices on the marriage day. Though they participated in the reception, the appellant's father took the bridegroom with him from the reception dais. Before the marriage reception concluded, the appellant went out from the reception dais and stood on the left side. The appellant refused to come up on the dais in spite of the bride's relatives pleading with him. The appellant, at that point, told the relatives that after 100 sovereigns were presented, they could speak. The photographer also deposed that the appellant's family did not coopearte even for taking wedding photos.The Court observed that the ingredients of the offence were made out."We are satisfied that the ingredients of Section 498-A of IPC are fully satisfied and that the appellant subjected PW- 4 (wife) to harassment with a view to coercing her and her mother to meet the unlawful demand for the gold sovereigns and continued to harass her when PW-4 and her relatives failed to meet such demand. The ingredients of Section 498-A of IPC and Section 4 of DP Act are clearly made out," the Court observed.However, the Supreme Court reduced his sentence to the sentence already suffered taking into account the mitigating factors such as the passage of time, the short-lived marriage, and the parties' subsequent conduct. The trial court had sentenced him to three years imprisonment.Given that the case was 19 years old, the couple had lived together for only three days, and both had since moved on with their lives, the Court found it appropriate to reduce the appellant's sentence. This decision was also influenced by the appellant's (IT Professional) potential for making positive contributions to society, which the Court recognized as a significant mitigating factor in sentencing. The bench comprising Justice K.V. Viswanathan and Justice S.V.N. Bhatti referred to the precedent set in Samaul Sk. vs. The State of Jharkhand & Anr., where the Court reduced the sentence of a man accused of a similar offense. The decision emphasized the reformative nature of criminal jurisprudence, noting that keeping the individual in jail would serve no meaningful purpose when mitigating factors weighed in the appellant's favor. Though in Samaul Sk's case, the convict offered to pay compensation to the victim, the Court in the present case directed the Appellant to pay Rs. 3,00,000/- (Three lakhs) monetary compensation to the de facto complainant for the benefit of her children. “On the special facts of the case, we think the ends of justice will be met if we adopt the course followed by this Court in the case of Samaul Sk. vs. The State of Jharkhand & Anr. (2021 INSC 429). This Court, in that case, while reducing the sentence to that of the period already undergone recorded the voluntary offer of the appellant to pay a monetary compensation of Rs. 3,00,000/- (Three lakhs) to the de facto complainant for the benefit of her children. No doubt in the present case, there is no voluntary offer, but we propose to direct payment of compensation.”, the court observed. Accordingly, the appeal was partly allowed in terms of the aforesaid observation. Case Title: M. Venkateswaran Versus The State Rep. by the Inspector of PoliceCitation : 2025 LiveLaw (SC) 117Click here to read/download the judgmentAppearance: For Petitioner(s) : Mr. M.P. Parthiban, AOR Mr. Bilal Mansoor, Adv. Mr. Shreyas Kaushal, Adv. Mr. S. Geyolin Selvam, Adv. Mr. Alagiri K, Adv. Mr. P.V.K. Deivendran, Adv. For Respondent(s) : Mr. D. Kumanan, AOR Ms. Deepa S, Adv. Mr. Sheikh F Kalia, Adv. Mr. Veshal Tyagi, Adv. Mr. Chinmay Anand Panigrahi, Adv. Ms. Shagufa Khan, Adv.

Groom Refuses To Cooperate With Wedding Reception Over Gold Demand; Supreme Court Upholds Conviction Under S.498A & Dowry Law

Yash Mittal

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