The Supreme Court has set aside the conviction of Rajesh Chaddha under Section 498A of the Indian Penal Code and Section 4 of the Dowry Prohibition Act, 1961, holding that allegations in such cases “cannot be ambiguous or made in thin air.” The Court emphasized the need for specific, substantiated claims to invoke penal provisions under these sections.
The Bench comprising Justice B. V. Nagarathna and Justice Satish Chandra Sharma passed the judgment in Rajesh Chaddha vs State of Uttar Pradesh [SLP (Crl.) Nos. 2353-54 of 2019], allowing the appeal and acquitting the appellant of all charges.
Background
The case originated from an FIR dated December 20, 1999, registered at Women Police Station, Lucknow, based on a complaint by Mala Chaddha, wife of the appellant. She alleged mental and physical cruelty for not bringing sufficient dowry, naming her husband and in-laws as accused. The complaint included claims of forced drugging, humiliation, assault during pregnancy resulting in miscarriage, and monetary demands, particularly a demand of ₹2 lakhs.
Trial Courts’ Findings
The Trial Court acquitted the accused of charges under Sections 323 read with 34 and 506 IPC due to lack of medical evidence but convicted Rajesh Chaddha under Section 498A IPC and Section 4 of the Dowry Prohibition Act, sentencing him to two years’ and one year’s rigorous imprisonment respectively. This conviction was upheld by the Sessions Court and the Allahabad High Court, which found no legal error or perversity in the trial court’s conclusions.
Supreme Court Observations
On appeal, the Supreme Court scrutinized the evidentiary foundation of the case and noted:
“In order to meet the threshold of the offences under Section 498A IPC & Sections 3 & 4 of the D.P. Act, 1961, the allegations cannot be ambiguous or made in thin air.”
The Court found that the allegations were “vague, omnibus and bereft of any material particulars.” It noted that apart from the depositions of the complainant and her father, there was no corroborative evidence such as medical records or specific details like dates or manner of harassment.
It also observed that the complaint was filed after the husband had initiated divorce proceedings, and the marriage had already been dissolved by a decree which attained finality.
On Misuse of Protective Provisions
The Court expressed concern over the growing misuse of Sections 498A IPC and Sections 3 & 4 of the Dowry Prohibition Act:
“The term ‘cruelty’ is subject to rather cruel misuse by the parties, and cannot be established simpliciter without specific instances, to say the least.”
Citing its previous judgment in Dara Lakshmi Narayana vs State of Telangana, the Court reiterated that sweeping allegations against all family members, without specific details, undermine the credibility of the complaint and constitute an abuse of legal process.
Decision
Setting aside the orders of the High Court and the courts below, the Supreme Court acquitted Rajesh Chaddha of all charges:
“Any further prosecution of the Appellant will only tantamount to an abuse of process of law.”
