The Supreme Court has ruled that merely advising a woman to “adjust” in her matrimonial life or return to her parental home does not amount to cruelty under criminal law. At the same time, the Court cautioned against the routine prosecution of a husband’s relatives in matrimonial disputes.
The ruling came in Arti Mehta & Ors. v. State of Madhya Pradesh & Anr. A Bench of Justices Sanjay Karol and N. Kotiswar Singh held that such advice may be insensitive or morally questionable. However, courts cannot treat it as a criminal offence unless there are specific allegations showing active involvement in the alleged wrongdoing.
Allowing an appeal filed by the husband’s relatives, the Court quashed criminal proceedings against them in a case involving allegations of cruelty, dowry harassment, and domestic violence.
No Automatic Criminal Liability for In-Laws
The Court stressed that family members do not become criminally liable simply because they support the husband, remain silent during disputes, or encourage reconciliation.
“Mere allegations that family members ‘supported’ the husband, failed to intervene, or advised the complainant to adjust in the matrimonial relationship, without anything further, would not ipso facto attract criminal liability,” the Court observed.
The Bench added that some relatives may remain passive spectators in a marital dispute. However, courts cannot treat such conduct as criminal unless evidence shows their active participation or complicity.
Vague Allegations Cannot Sustain Prosecution
The Court found that the allegations against the husband’s relatives were vague and general in nature. The complaint did not describe any specific incident, overt act, or unlawful dowry demand by any of the appellants.
“No independent or specific role has been attributed to any of the present appellants so as to disclose prima facie commission of offences under Sections 498A/34 IPC or Sections 3 and 4 of the Dowry Prohibition Act,” the Bench noted.
Background of the Case
The dispute arose from a marriage solemnised in 2019. The complainant alleged that her husband and his family subjected her to mental and physical cruelty and demanded dowry.
Based on her complaint, police registered an FIR under Sections 498A and 34 of the Indian Penal Code and Sections 3 and 4 of the Dowry Prohibition Act. She also initiated proceedings under the domestic violence law.
A Magistrate Court in Guna took cognisance of the complaint and issued process against all accused persons, including the husband’s mother, brother, sister, and sister-in-law. The Madhya Pradesh High Court later refused to quash the proceedings against the relatives.
Supreme Court’s Analysis
The Supreme Court disagreed with the High Court. It noted that most allegations targeted the husband. The accusations against the other family members remained general and unsupported by specific facts.
The Court also noted that the complainant mainly lived with her husband in Sheopur. Meanwhile, the in-laws lived separately in Shivpuri. This fact weakened the claim that they continuously harassed her.
The Bench further noted that the marriage had already ended in divorce during the pendency of the proceedings.
Given these circumstances, the Court held that continuing the criminal case against the relatives would amount to an abuse of the legal process.
Warning Against Misuse of Criminal Law
The Court highlighted the need for careful scrutiny in matrimonial disputes.
“It is not uncommon that when matrimonial relationships deteriorate, allegations are made in the heat of emotional turmoil… often resulting in the entire family of the spouse being drawn into criminal litigation,” the Bench observed.
The Court reiterated that parties should not use criminal law to settle personal grievances or scores. It stressed that courts must prosecute relatives only when clear, specific, and credible allegations exist against them.
