‘Lack Of Specific Allegations’: SC Grants Relief To Husband, Kin In Dowry Harassment Case
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The case, originating from allegations of domestic abuse filed by the man’s wife, was escalated to the Supreme Court following the high court’s refusal to quash the charges despite arguments that the accusations were vague and lacked specific evidence
The Supreme Court, in a recent judgment, set aside an order by the Madras High Court, granting relief to a man, his mother and maternal uncle in a case registered under Section 498A of the Indian Penal Code (IPC).
The case, originating from allegations of domestic abuse filed by the man’s wife, was escalated to the Supreme Court following the high court’s refusal to quash the charges despite arguments that the accusations were vague and lacked specific evidence.
The case began with a complaint filed in August 2019 by the second respondent, the man’s wife, who alleged cruelty and harassment by her husband and his family members. Following an investigation, a charge sheet was filed in Coimbatore under Section 498A, which penalises acts of cruelty against a married woman. The appellants (the husband and his family members) sought to dismiss this charge sheet, arguing that the allegations were unsubstantiated and general, lacking the required specificity to establish a clear case under Section 498A.
The appellants approached the Madras High Court to quash the charges under Section 482 of the Criminal Procedure Code (CrPC), a provision that allows courts to dismiss cases if the charges are found to be frivolous or an abuse of the legal process. However, the high court dismissed their plea, stating that prima facie there was sufficient material on record for the case to proceed.
Upon further appeal, the Supreme Court scrutinised the charge sheet and found the accusations against the man and his family members to be “vague” and lacking the necessary details to substantiate the charges.
The court cited precedents, including Umesh Kumar v. State of Andhra Pradesh and Dhanlakshmi v. R. Prasanna Kumar, which highlight the judiciary’s power to quash proceedings that appear to misuse the legal process.
It underscored that under Section 482, courts have the inherent authority to dismiss cases where allegations are insubstantial or intended to harass the accused.
It further observed that rejecting an application could not be rejected merely on the grounds that the accused could argue legal and factual issues at the time of framing of the charges.
In its judgment, delivered by the bench of Justices CT Ravikumar and Sanjay Karol, the Supreme Court emphasised the importance of safeguarding individuals from baseless allegations. It observed that permitting the proceedings to continue based on such general accusations would constitute an abuse of judicial resources and cause unwarranted hardship to the appellants.
Accordingly, the court allowed the appeal and quashed the further proceedings in the matter.