Supreme Court Ruling: A husband emerges victorious in false challenging cases under Section 498A, SC/ST Atrocities Act, and Dowry Act, filed by his wife five years ago as an act of personal vendetta. The wife had also accused him of being a sex maniac and a drug addict, but all allegations were proven false. Read below to discover the legal arguments that led to his victory in the Supreme Court.
Sometimes, marrying the love of your life doesn’t guarantee a successful marriage and can even become a nightmare. A Brahmin man faced a challenging Cases ordeal when his wife, from a Scheduled Caste (SC) background, left him after two years of marriage and filed cases under the Dowry Act, Section 498A, and the SC/ST Atrocities Act, leveling multiple allegations against him.
Based on her allegations, the police filed a chargesheet in 2019 against her husband and in-laws, invoking Sections 498A, 504, and 506 of the Indian Penal Code, along with the Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act, 1989, and the Dowry Prohibition Act, 1961. In 2023, the High Court granted partial relief to the husband by quashing the charges under the SC/ST Act, as well as Sections 504 and 506. However, it declined to dismiss the criminal proceedings related to Section 498A and the Dowry Prohibition Act, 1961, prompting them to seek justice from the Supreme Court.
Meanwhile, alongside these criminal proceedings, a separate divorce case was ongoing in the family court.
Read below to discover how the family court’s judgment helped establish that the wife filed false criminal cases out of personal vendetta, and how the husband not only won the case but also secured relief for his parents.
Mysore Family Court Rules That Wife Inflicted Cruelty on Husband, Not the Other Way Around
The wife accused her husband of being a “sex maniac” and a “drug addict.” She further claimed that her father had made multiple payments to her husband for rent, foreign travel, and other expenses in response to his demands. Additionally, she alleged that her in-laws harassed her and made caste-based remarks whenever they visited them in Bangalore, where the couple lived.
Contrary to the wife’s claims of her husband being a sex maniac and a drug addict, the family court dismissed these allegations.
In its order dated August 19, 2023, the Additional Principal Judge of the Family Court at Mysuru made the following observations:
- The wife falsely alleged that a car was gifted during the marriage and that her father provided financial assistance for her husband’s foreign trips.
- The evidence presented conclusively established that the accusations of the husband being a drug addict and a sex maniac were made solely to gain an unfair advantage in both the divorce and criminal proceedings.
The Family Court determined that the wife had made numerous unfounded and baseless allegations against her husband, subjecting him to cruelty. As a result, the court granted a divorce decree on the grounds of cruelty.
Supreme Court Warns Against Misuse of Section 498A for Personal Vendetta
The Supreme Court strongly condemned the misuse of Section 498A in its order dated January 15, 2025, stating:
“Criminal law should not be weaponized for harassment or personal vendetta. Allegations in a criminal complaint must be carefully scrutinized to ensure they establish a prima facie case before subjecting individuals to the rigors of a criminal trial.”
The Court further emphasized:
“Cases involving allegations under Section 498A of the IPC and the Dowry Prohibition Act require a cautious and balanced approach to prevent misuse. While these provisions are meant to protect women from cruelty and dowry harassment, they should not be exploited to settle personal scores or serve ulterior motives.”
“In the present case, the allegations against the appellants lacked merit, were blatantly frivolous, and failed to establish a prima facie case. Allowing the criminal proceedings to continue under such circumstances would constitute an abuse of the legal process and lead to a miscarriage of justice.”
Nikhil Varshney, Partner at Cyril Amarchand Mangaldas, stated: “This judgment reaffirms that criminal law should not be misused as a tool for personal vendettas and emphasizes the need for courts to exercise thorough scrutiny to prevent vexatious litigation under protective legislation.”
How did the Supreme Court determine that the wife filed a false 498A case out of personal vendetta?
The Supreme Court divided the criminal cases into two segments—one against the in-laws and the other against the husband.
The criminal case against the in-laws (husband’s parents) lacked specific details:
“Upon careful examination of the submissions and evidence on record, it is evident that the allegations against the father-in-law and mother-in-law are vague and lack specificity. The complainant has failed to provide concrete details regarding dowry demands or acts of cruelty attributed to them. Moreover, the acknowledged fact that they reside separately further weakens the case against them. In the absence of prima facie evidence establishing their involvement in the alleged offenses, the proceedings against the father-in-law and mother-in-law cannot be sustained.”
The criminal case against the husband lacked evidence:
“With regard to the husband, the allegations are similarly vague and unsubstantiated. The complainant (wife) has made broad accusations without providing specific instances of misconduct. No concrete allegations or material evidence have been presented to establish a prima facie case of cruelty or dowry demand. It is acknowledged on record that the couple had a love marriage and shared a harmonious relationship in the initial years. This, along with the absence of substantive evidence, leads to the conclusion that no prima facie case of cruelty or dowry demand is made against the husband. In the absence of sufficient evidence, criminal proceedings cannot be allowed to continue.”
Supreme Court: Mysore Family Court’s Findings Exposed Wife’s Ulterior Motive Behind Filing 498A Case
The Supreme Court gave significant weight to the observations of the Mysore Family Court, as the Additional Principal Judge was able to uncover the wife’s true intentions.
The Supreme Court stated:
As evident from the record, the marriage between the parties has been dissolved, with clear findings that the complainant subjected the appellant-husband to cruelty.
The allegations in the criminal complaint—pertaining to dowry demand, cruelty, and harassment—have been deemed baseless, false, and frivolous. While these are separate proceedings, the findings regarding the truth and credibility of such serious accusations are crucial to ensuring justice and preventing the misuse of the criminal justice system.
The Family Court has made clear findings establishing that the allegations are false, with no evidence presented to support their validity. Even in the criminal proceedings challenged before us, no material has surfaced to indicate the commission of the alleged acts, even on a prima facie basis.
Once it has been determined that the allegations lack merit or truthfulness, allowing criminal proceedings based on the same accusations to continue would only enable the misuse of the criminal justice system.
“Accordingly, the appeals are upheld, and the criminal proceedings under Section 498A of the IPC and Sections 3 and 4 of the Dowry Prohibition Act against all appellants are hereby quashed,” as stated in the Supreme Court’s order.
Key Legal Takeaways from the Judgment
ET Wealth Online consulted legal experts to understand the key takeaways from this ruling. Here’s what they had to say:
Nidhi Mohan Parashar, AOR, Supreme Court of India & Partner, Vedya Partners:
“This judgment exemplifies how the Supreme Court of India is actively working to prevent the misuse of criminal law and is taking a firm stance against wives who exploit the legal system to settle personal disputes. The Supreme Court’s approach to quashing FIRs related to matrimonial offenses has been more balanced compared to that of the high courts.”
Shiv Sapra, Partner, Kochhar & Co:
“This ruling reinforces what courts have been cautioning against for nearly two decades. Since the case of Sushil Kumar Sharma vs. Union of India, concerns about frivolous and vexatious complaints have persisted. More recently, in Dara Lakshmi Narayana vs. State of Telangana, the Supreme Court once again condemned the misuse of legal provisions.”
This judgment reinforces established legal principles and should serve as both a deterrent and a warning to those who attempt to misuse legal remedies as a tool for personal gain.
Ankit Rajgarhia, Principal Associate, Karanjawala & Co:
*”This judgment reaffirms that Section 498A of the IPC should not be misused as a tool for harassment or personal vendetta. It underscores the necessity for criminal proceedings to be based on specific, clear, and prima facie evidence rather than vague or generalized allegations.
Additionally, the ruling acknowledges that findings from civil proceedings—such as a Family Court granting divorce on cruelty grounds—can be considered in criminal cases when the allegations overlap. If a court has already determined that the accusations are false, it strengthens the case for quashing related criminal proceedings.
Courts must exercise caution while handling cases under Section 498A IPC and the Dowry Prohibition Act to prevent their misuse for personal vendettas. This aligns with previous Supreme Court rulings, such as Rajesh Sharma & Ors. v. State of U.P. (2017) and Arnesh Kumar v. State of Bihar (2014), which also warned against the misuse of these provisions.”*
Key Legal Insights from Experts on the Judgment
Nikhil Varshney, Partner, Cyril Amarchand Mangaldas:
The Supreme Court has emphasized that general allegations, without specific instances or material evidence, do not meet the prima facie threshold required to sustain prosecution. The ruling also highlights the Court’s recognition that laws intended for protection can sometimes be misused, leading to a loss of trust in the legal system.
Prachi Dubey, Advocate, Delhi High Court:
This judgment sets a crucial precedent that criminal proceedings under Section 498A IPC and the Dowry Prohibition Act should not proceed in the absence of prima facie evidence. It reinforces that vague, baseless, or generalized allegations—especially in matrimonial disputes—should not be weaponized to harass individuals or exploit the criminal justice system. Courts must exercise due diligence to prevent such misuse.
Alay Razvi, Managing Partner, Accord Juris:
The ruling underscores the judiciary’s cautious approach in cases of alleged cruelty and dowry harassment, ensuring that these provisions are not misused for personal vendetta. Section 498A was introduced to protect married women from cruelty by their husbands and in-laws. However, over time, it has been exploited to target not only husbands but also their families and even distant relatives.
A thorough investigation should precede the filing of such complaints, and if a case is found to be false, appropriate legal action should be taken against the complainant. The judgment reinforces safeguards against arbitrary prosecution of a husband’s extended family, emphasizes judicial scrutiny in dowry-related allegations, and calls for legislative and procedural reforms to prevent misuse of legal provisions.
Shashank Agarwal, Advocate, Delhi High Court:
Marriage is a sacred bond between two individuals, built on the promise of lifelong companionship. However, when marriages break down, they often do so on a bitter note. Laws like Section 498A IPC, the Dowry Prohibition Act, and the Domestic Violence Act were enacted to protect women from cruelty.
Unfortunately, these provisions have been increasingly misused by wives and their families as a means to settle scores or recover wedding expenses. This judgment sets a strong precedent against the wrongful use of such laws for personal gain by making baseless allegations.