Laws Intended To Protect Women From Cruelty & Dowry Harassment Shouldn't Be Misused To Settle Personal Scores : Supreme Court

The Supreme Court recently, while quashing a case involving allegations of cruelty and dowry said that criminal law should not be used as a tool for harassment. It added that courts must be cautious while dealing with such cases to prevent misuse of the law. While the provisions are intended to protect women from cruelty and dowry harassment, they should not be used to settle personal scores or pursue ulterior motives., the Court said.

“Criminal law should not be used as a tool for harassment or vendetta. The allegations in a criminal complaint must be scrutinized with care to ensure that they disclose a prima facie case before subjecting individuals to the rigors of a criminal trial. The cases involving allegations under Section 498-A of the IPC and the DP Act often require a careful and cautious approach to prevent misuse of the law. While the provisions are intended to protect women from cruelty and dowry harassment, they should not be used to settle personal scores or pursue ulterior motives.”

To provide a brief background, the above case was filed against the present appellants i.e., in-laws and husband of the complainant. Challenging this, the appellants approached the High Court seeking quashing of the criminal proceedings. However, observing that a prima facie case had been made out against the appellants for cruelty and dowry demands, the Court refused to quash the case. Thus, the present appeal.

The Bench of Justices Vikram Nath and Sandeep Mehta noted that the family court has already allowed the divorce petition filed by the appellant/ husband. In its order, the family court had recorded that the complainant made several bald and baseless allegations against him and thereby treated him with cruelty.

Building on this and perusing the submissions, the Apex Court also found that the allegations against the in-laws were general with no specific details of the above allegations.

“The complainant has not provided any concrete details of dowry demands or acts of cruelty attributable to them. The admitted fact of their separate residence further weakens the complainant's case against them. In the absence of prima facie evidence to establish their involvement in the alleged offenses, the proceedings against the father-in-law and mother-in-law cannot be sustained.,” the Court reasoned.

Adverting to the allegations against the husband, the Court termed the same as vague and unsubstantiated. With no specific allegations and material, the Court concluded that no prima facie case was made against the husband. Criminal proceedings cannot be permitted to continue in the absence of sufficient evidence to prima facie establish the commission of an offense., the Court said.

“In the present case, the allegations against the appellants were devoid of merit, manifestly frivolous and fail to disclose a prima facie case. The continuation of criminal proceedings in such circumstances would amount to an abuse of the process of law and result in a miscarriage of justice,” the Court held while allowing the present appeals and quashing the above criminal proceedings.

Appearances:

Petitioners: Mr. Shailesh Madiyal, Sr. Adv. Mr. Mahesh Thakur, AOR Ms. Divija Mahajan, Adv. Mr. Anchit Singla, Adv. Mr. Ranvijay Singh Chandel, Adv. Mrs. Geetanjali Bedi, Adv.

Respondent: Mr. D. L. Chidananda, AOR Mr. Mrigank Prabhakar, AOR Mr. Siddharth Ssahu, Adv.

Case Name: P.V. KRISHNABHAT vs. THE STATE OF KARNATAKA., Special Leave to Appeal (Crl.) No(s). 1754/2024

Citation : 2025 LiveLaw (SC) 149

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