Section 498A IPC: Supreme Court Clarifies Allegations Must Specify Acts of Cruelty

The bench stressed, "In such cases involving allegations of cruelty and harassment, there would normally be a series of offending acts, which would be required to be spelt out by the complainant against perpetrators in specific terms to initiate criminal proceedings against them. Therefore, mere general allegations of harassment without pointing out the specific details would not be sufficient to continue criminal proceedings against any person".

The appeal was filed by one Shobhit Kumar Mittal challenging the refusal by the Allahabad High Court to quash a 2023 FIR lodged by his sister-in-law against him, his brother (the complainant's husband), and his mother. The allegations in the FIR pertained to Sections 323 and 498A of the IPC and Sections 3 and 4 of the Dowry Act.

The top court noted that a bare perusal of the FIR showed that the allegations made by the complainant were vague and omnibus. Other than claiming that the husband and his family along with the appellant, mentally harassed her with a demand for dowry, she had not provided any specific details or described any particular instance of harassment.

The bench stated, "She has also not mentioned the time, date, place, or manner in which the alleged harassment occurred or the details of the nature of demand or its particulars. Therefore, the FIR lacks concrete and precise allegations".

The bench further emphasised that merely stating that the appellant had mentally harassed her with respect to a demand for dowry did not fulfill the ingredients of Section 498A of IPC specially in absence of any cogent material or evidence on record to substantiate the said allegations.

The bench stressed that courts have to be careful and cautious in dealing with complaints and must take pragmatic realities into consideration while dealing with matrimonial disputes where the allegations have to be scrutinized with great care and circumspection in order to prevent miscarriage of justice and abuse of process of law.

Relying upon judicial tests laid down in State of Haryana vs. Bhajan Lal (1992), the bench observed, "We find that none of the offences alleged against the accused/ appellant herein is made out. In fact, we find that the allegations of cruelty, mental harassment and voluntarily causing hurt against the accused/appellant herein are vague and general in nature".

In the facts of this case, the court held, it was neither expedient nor in the interest of justice to permit the present prosecution emanating from the FIR to continue.

The bench quoted its earlier decision in Dara Lakshmi Narayana vs. State of Bihar (2025), which stated, "There has been a growing tendency to misuse provisions like Section 498A of the IPC as a tool for unleashing personal vendetta against the husband and his family by a wife. Making vague and generalised allegations during matrimonial conflicts, if not scrutinized, will lead to the misuse of legal processes and an encouragement for use of arm-twisting tactics by a wife and/or her family".

Court thus set aside the high court's order and quashed the FIR lodged on November 09, 2023, at Police Station Civil Lines, Meerut and all consequent proceedings only qua the appellant.

Case Title: Shobhit Kumar Mittal Vs State of Uttar Pradesh & Another

Judgment Date: September 24, 2025

Bench: Justices B V Nagarathna and R Mahadevan