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Synopsis

In a significant ruling, the Madhya Pradesh High Court has held that objections raised by the mother-in-law concerning household chores of her daughter-in-law cannot reasonably be deemed as falling under the classification of cruelty.

The court, presided over by Justice Gurpal Singh Ahluwalia noted, “If mother-in-law was objecting to certain household works of her daughter-in-law, then by no stretch of imagination it can be said that such act of the mother-in-law would fall within the category of cruelty as defined under Section 498-A of IPC.”

The court further said, “If daughter-in-law gets mental harassment on account of certain objections raised by her mother-in-law in the household works, then it can be said that daughter-in-law may be hypersensitive. But, certain disputes with regard to household works would certainly not amount to cruelty as cruelty.”

The court made the observation while addressing an application under Section 482 of Cr.P.C. filed to quash an FIR registered under Sections 498-A, 506 read with Section 34 of the Indian Penal Code (IPC), and Sections 3 and 4 of the Dowry Prohibition Act.

In this instance, the daughter-in-law, identified as Respondent no. 2, filed the FIR, alleging mental and physical harassment by her husband, who is the son of the applicant. Despite the marriage being a love marriage, it was plagued by continuous interference from the applicant and demands for dowry from the husband. The husband's behaviour deteriorated over time, escalating to threats of divorce and physical violence. Respondent no. 2 expressed concern about her husband's intention to leave the country and requested the seizure of his passport. Despite attempts at reconciliation by her parents, the situation remained unresolved.

The bench noted that the allegation of the mother-in-law's non-intervention in disputes between her son and daughter-in-law does not amount to cruelty, particularly if she chose to refrain from involvement in personal matters.

Additionally, the fact that the mother-in-law relocated to a foreign country and is residing with her daughter and son-in-law in America signifies a physical separation from the situation.

“A bald allegation that respondent no. 2 was deprived of love and affection of her mother-in-law would also not amount to cruelty,” the court said considering the overall circumstances of the case.

The court concluded that according to the applicant's argument, even if all the allegations were accepted, it cannot be asserted that there was any deliberate act or behaviour on the part of the applicant that could have compelled the daughter-in-law to contemplate or commit suicide.

The High Court expressed the opinion that even if all the allegations in the FIR were accepted at face value, no offences under Sections 498-A, 506/34 of IPC read with Section 3/4 of the Dowry Prohibition Act would be established.

In light of the observations made, the bench granted the application and the FIR was quashed.

Case Title: Alka Sharma v State of MP [MISC. CRIMINAL CASE No. 30092 of 2022]