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Synopsis

The Supreme Court has emphasized the need for a careful and cautious approach in cases of dowry harassment allegations to prevent misuse of the law. While these provisions are intended to protect women from cruelty and dowry-related abuse, the court warned that they should not be exploited to settle personal scores or pursue ulterior motives.

A bench of Justices Vikram Nath and Sandeep Mehta allowed a criminal appeal by a man and his parents to quash a criminal case initially lodged under Section 498-A, 504, 506 of IPC, Sections 3(1)(r), 3(1)(s) and 3(1)(w) of the Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act, 1989,2 and Sections 3 and 4 of the Dowry Prohibition Act, 1961 on a complaint filed by his wife.

The high court had only partly allowed their plea to quash the case against them, refusing to quash the proceedings under Section 498A and Sections 3 and 4 of the DP Act.

Having examined their appeal against the high court's decision, the apex court noted that the allegations against the appellants were devoid of merit, manifestly frivolous, and failed 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", it held.

"Criminal law should not be used as a tool for harassment or vendetta. The allegations in a criminal complaint must be scrutinised with care to ensure that they disclose a prima facie case before subjecting individuals to the rigors of a criminal trial," the bench said.

In the complaint lodged on February 10, 2019, the woman had alleged cruelty and harassment at the hands of the appellants. The complainant alleged that that at the time of marriage, a swift car, a gold chain of 80 grams, a ring, and a bracelet weighing about 50 grams, among other gifts were given and the marriage was performed at an expense of Rs 45,00,000.

She claimed that she belonged to a scheduled caste, while the husband belonged to the Brahmin caste, and that they fell in love with each other and thereafter got married. She further claimed that her father had paid several amounts to the husband for rent, his foreign travels, etc upon demands made by him. She also alleged that he was addicted to alcohol and drugs, and used to mentally harass her. Further, she claimed that her in-laws would also harass her and make caste-based remarks whenever they used to visit them in Bangalore, where the couple was residing.

As the police filed the charge sheet and the trial court took cognizance of the offences alleged, the appellants approached the Karnataka High Court which said the allegations contained charges of cruelty and dowry demands, and it required examination by the trial court.

The high court also noted that the allegations against the father-in-law and mother-in-law were largely general and lacked specificity. Despite this, it chose not to quash the proceedings against them under Section 498-A of the IPC, reasoning that the allegations required further scrutiny at trial.

Before the apex court, despite service, no one appeared on behalf of the complainant.

In their arguments, the appellants contended the proceedings in the case were baseless and constituted an abuse of the process. The parents of the man admittedly resided separately, negating any reasonable possibility of their involvement in the alleged acts of cruelty or dowry demands.

Moreover, they said the allegations were general and omnibus in nature, lacking any specific instances of misconduct or unlawful demands.

On behalf of the husband, it was submitted that the allegations against him were equally vague and devoid of substantive evidence. He said that it was a love marriage and they enjoyed a harmonious relationship for the first two years of their married life, which undermined the complainant's allegations of cruelty and harassment.

He also submitted that the case had been filed as a counterblast and owing to the failure of the marriage between the parties. The continuation of criminal proceedings against the husband, father-in-law, and mother-in-law in the absence of prima facie evidence amounted to harassment and would cause irreparable harm to their reputation and dignity, the appellants' counsel said.

The appellants also submitted the Family Court at Mysuru had allowed the divorce petition filed by the appellant-husband, through an order on August 19, 2023, on the grounds of cruelty.

The Family Court had also held that the complainant had made false allegations regarding the gifting of a car during marriage and extending of financial help by her father for the husband’s foreign trips. It had also said that the allegations of the husband being a drug addict and a sex maniac had been made only to take unreasonable advantage in the divorce as well as the criminal proceedings. It had also concluded that the wife (complainant) had made several bald and baseless allegations against the husband and thereby treated the husband (appellant-accused) with cruelty, and thus the cour had granted a decree of divorce on the said grounds.

The apex court found that the allegations against the parents were indeed general and lacked specificity and their separate residence weakened the complainant's case, holding that the proceedings against them could not be sustained.

Regarding the husband, the court said, it was evident that the allegations against him were similarly vague and unsubstantiated. The complainant has made generalised accusations without furnishing specific instances of misconduct, the apex court held.

"No specific allegations and neither any material have come on record to show a prima facie commission of the alleged offences of cruelty and dowry demand. The couple had a love marriage and experienced a blissful relationship during the initial years of their marriage, as is admitted on record. This, coupled with the lack of material evidence to support the allegations, leads to the conclusion that no prima facie case of cruelty or dowry demand is made out against the husband as well," the bench said.

The court also noted the marriage between the parties had been dissolved and allegations made in the criminal complaint, regarding dowry demand, cruelty, and harassment had all been held to be baseless, false, and frivolous.

"Though, these are separate proceedings, but findings regarding the truth and veracity of such serious allegations, as have been made by the complainant herein, become relevant in order to do justice and avoid misuse of criminal justice system. The Family Court has made categorical findings to hold that the allegations are false and nothing has been produced to or prove any merit in the allegations," the bench said.

Even in the impugned criminal proceedings, the bench pointed out, nothing had come on record to show commission of these alleged acts, even on a prima facie analysis.

"Once it has been held that there is no merit or truthfulness to the allegations made, then criminal proceedings on the very same allegations cannot be allowed to continue and propagate misuse of the criminal justice system," the bench said.

The court quashed the criminal proceedings, holding the allegations against the appellants were devoid of merit, manifestly frivolous and failed 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 bench held.

Case Title: P V Krishnabhat & Anr Vs State of Karnataka & Ors