In a judgment delivered on April 9, 2025, the Supreme Court held that the acquittal of accused persons in a dowry-related criminal trial does not preclude the return of dowry articles under Section 6(3) of the Dowry Prohibition Act, 1961. The ruling came in Nirmala Chauhan vs State of Uttar Pradesh & Ors., Criminal Appeal No. ___ of 2025 (arising out of SLP (Crl.) No. 7899 of 2024), decided by a Bench comprising Justice Manoj Misra and Justice Rajesh Bindal.
Background of the Case
The appellant, Nirmala Chauhan, is the mother of the deceased woman. She filed an application under Section 6(3) of the Dowry Prohibition Act seeking the return of dowry articles from the family of the deceased’s husband. The Additional Chief Judicial Magistrate, Ghaziabad, dismissed the application in Complaint No. 2336 of 2022 on October 31, 2023, primarily on the ground that the accused had been acquitted in the related criminal case.
The Allahabad High Court, in Criminal Revision No. 404 of 2024, upheld the Magistrate’s order and dismissed the revision on April 16, 2024.
Submissions by Parties
The appellant contended that the acquittal of the accused in the criminal trial should not affect the maintainability of the application under Section 6(3) of the Dowry Prohibition Act. It was argued that the High Court failed to address whether the application was maintainable and whether summary dismissal was justified.
On the other hand, the learned counsel for the respondents submitted that the application was not maintainable as the charge of dowry demand was not proved in the criminal trial. They also argued that the application was barred by limitation.
Observations of the Supreme Court
The Court examined the orders of the Magistrate and the High Court and observed:
“Neither the learned Magistrate nor the High Court has dismissed the complaint on the ground that it was barred by limitation.”
Therefore, the Court declined to express any opinion on the limitation issue.
However, addressing the primary reason for dismissal, the Bench held:
“Acquittal of the accused in criminal trial would not warrant rejection of the application for return of the dowry articles. If dowry articles are given without a demand, regardless whether an offence under the Act is committed, they still may have to be returned in view of the provisions of the Act considering that in absence of any children of the deceased, the mother would be the natural heir of the deceased.”
Final Decision
The Supreme Court concluded that the High Court had not addressed all relevant aspects while dismissing the revision petition. Accordingly, it set aside the High Court’s order and directed restoration of Criminal Revision No. 404 of 2024 for fresh adjudication in accordance with law.
The Court clarified:
“Any observation made by us in this order shall not prejudice the High Court in forming its own view.”
The appeal was allowed, and all pending applications were disposed of.
