The Supreme Court of India has once again underscored the need for judicial prudence in matrimonial disputes, cautioning against the over-implication of distant relatives in such cases. In a significant judgment delivered in Criminal Appeals arising from SLP (Crl.) Nos. 3995 of 2022 and 13579 of 2023, the court quashed an FIR filed against distant relatives in a matrimonial dispute, while emphasizing the duty of courts to differentiate between genuine allegations and exaggerated claims.
The bench, comprising Justice C.T. Ravikumar and Justice Rajesh Bindal, delivered the verdict while addressing appeals filed by Payal Sharma (Accused No. 5) and Subhash Chander Kapila, the complainant, against the decision of the Punjab and Haryana High Court. The High Court had quashed the FIR against one accused but refused to extend similar relief to others.
Background of the Case
The case revolved around an FIR registered by Subhash Chander Kapila, the father of Vandana Sharma, against her husband Amit Sharma (Accused No. 1) and other family members, including Payal Sharma (Accused No. 5) and her husband (Accused No. 6). Vandana Sharma had married Amit Sharma in 2019, but the marriage soon fell apart, leading to a divorce in Canada in 2020. The complainant alleged cruelty under Section 498-A IPC and cheating under Sections 420 and 120-B IPC against multiple family members.
Payal Sharma and her husband, who resided in Mohali, were accused of being involved in the harassment and financial exploitation of Vandana Sharma. They argued that the allegations were vague and unfounded, pointing out that they lived in a different city and had no direct involvement in the matrimonial issues.
Key Observations by the Supreme Court
The Supreme Court overturned the High Court’s refusal to quash the FIR against Payal Sharma, emphasizing the following:
1. Over-Implication of Relatives:
– Referring to previous rulings, including Preeti Gupta v. State of Jharkhand and Geeta Mehrotra v. State of Uttar Pradesh, the court reiterated that vague and generalized allegations often lead to the unwarranted harassment of distant relatives in matrimonial disputes.
– “Courts must scrutinize allegations with care and circumspection to avoid implicating those not directly connected to the marital discord,” the bench observed.
2. Definition of Relatives under Section 498-A IPC:
– The court clarified that the term “relative” in matrimonial cases does not extend to distant relations who are not actively involved in the family dynamics or the alleged incidents.
3. Role of Evidence:
– The court noted that the FIR and subsequent investigation lacked specific evidence linking Payal Sharma and her husband to any cognizable offense.
– “The allegations against the accused were of a general and omnibus nature, devoid of substantive evidence,” the bench observed.
4. Judicial Responsibility in Matrimonial Cases:
– The judgment highlighted the duty of courts to act as a safeguard against the misuse of criminal law provisions, particularly in family disputes.
– “Even ultimate acquittal in a criminal trial cannot erase the stigma and suffering caused by unwarranted prosecution,” the court emphasized.
Supreme Court’s Decision
– The court quashed the FIR against Payal Sharma (Accused No. 5) and her husband (Accused No. 6), ruling that the proceedings constituted an abuse of the judicial process.
– It upheld the High Court’s decision to quash the FIR against Accused No. 6 but found fault in its refusal to extend similar relief to Accused No. 5.
– “The same principles must apply uniformly to both accused when the allegations are equally baseless,” the bench noted.
“Courts have to be extremely careful and cautious in dealing with these complaints and must take pragmatic realities into consideration while dealing with matrimonial cases,” the court stated.
Case Details
– Case Title: Payal Sharma v. State of Punjab & Anr.
– Bench: Justice C.T. Ravikumar and Justice Rajesh Bindal
– Lawyers: Senior Advocate Dr. Naveen Rawal represented the appellants.
