SUPREME COURT: CAUTION NEEDED IN CRIMINAL CASES INVOLVING FAMILY RELATIONS

On January 7, the Supreme Court, while dismissing criminal charges of cruelty, dowry demand, and domestic violence against the present appellants, emphasized the serious repercussions of invoking criminal laws in domestic disputes without specific allegations and credible evidence. The Court observed that the misuse of legal provisions in such cases could lead to severe consequences for families, potentially disrupting relationships, tarnishing reputations, and causing undue distress to the accused. It underscored the importance of judicial scrutiny to prevent frivolous or unsubstantiated complaints from being weaponized in personal conflicts.

“Domestic relationships, such as those between family members, are guided by deeply ingrained social values and cultural expectations. These relationships are often viewed as sacred, demanding a higher level of respect, commitment, and emotional investment compared to other social or professional associations. For the aforesaid reason, preservation of family relationship has always been emphasised upon. Thus, when family relationships are sought to be brought within the ambit of criminal proceedings rupturing the family bond, courts should be circumspect and judicious, and should allow invocation of criminal process only when there are specific allegations with supporting materials which clearly constitute criminal offences.,” the bench of Justices B.V. Nagarathna and Justice Nongmeikapam Kotiswar Singh added.

The criminal case pertained to offences under Section 498A and Section 506 of the Indian Penal Code, along with Sections 3 and 4 of the Dowry Prohibition Act, 1961. The appellants filed a special leave petition seeking the quashing of criminal proceedings initiated against them on allegations of cruelty and dowry demand. However, the High Court, in its impugned judgment, refused to quash the proceedings, stating that a prima facie case had been established against the appellants. Aggrieved by this decision, they approached the Supreme Court for relief. Notably, the appellants included the complainant’s mother-in-law, the mother-in-law’s younger sister, and her brother-in-law.

At the outset, the Court examined the charge sheet and the complaint. It noted that the investigating agency had relied on statements from the complainant, her parents, and two panchayat elders. After reviewing their testimonies, the Court observed that the harassment allegations were based on what the complainant had conveyed to her parents, rather than first-hand accounts. Consequently, the parents had not personally witnessed the alleged harassment.

“It may also be noted that as regards the alleged act of beating of the complainant by her husband and other relatives mentioned by the parents, the complainant herself does not mention so in her complaints. Therefore, this allegation of beating of the complainant is something which has been added by the father and the mother of the complainant though they did not themselves witness the same,” the Court added.

Furthermore, the Court analyzed the statements of the other two witnesses and found that their testimonies amounted to hearsay evidence. Significantly, the Court also noted that, although these panchayat elders were residents of Telangana, there was no explanation as to how they were present at the Panchayat meetings held in Chennai.

Before concluding, the Court clarified that these observations would not apply in cases where relatives have actively engaged in cruelty against the victim. It emphasized that each case of domestic violence must be assessed based on its unique facts and circumstances. Considering the factual background, the Court found that no prima facie case had been established against the appellants. It noted that the evidence against them solely relied on the complainant’s statements, without assigning any specific role to them. Consequently, the criminal proceedings against the appellants were quashed, while explicitly stating that these findings would not impact the proceedings against the other accused persons.