In a significant ruling, the Supreme Court of India quashed the criminal proceedings against P.V. Krishnabhatt, his wife, and their son, stating that criminal law should not be misused as a tool for harassment or vendetta. The bench comprising Justice Vikram Nath and Justice Sandeep Mehta delivered the judgment in Criminal Appeal No. 2025 of 2025 (arising from SLP (Crl.) No. 1754/2024) and SLP (Crl.) No. 2966/2024, bringing an end to the legal battle that began with a complaint filed in 2019.
Background of the Case
The case originated from a complaint lodged by the appellant’s daughter-in-law on February 10, 2019, alleging dowry harassment, cruelty, and caste-based discrimination. Following the complaint, an FIR in Crime No. 82/2019 was registered against the appellants under Section 498-A (cruelty) of the Indian Penal Code (IPC), Sections 3 and 4 of the Dowry Prohibition Act, 1961, and Sections 3(1)(r), 3(1)(s), and 3(1)(w) of the Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act, 1989.
The complainant alleged that at the time of her marriage, substantial dowry, including a car and jewelry, was given, and that she faced continuous harassment from her husband and in-laws. She further claimed that caste-based remarks were made against her and that her husband was addicted to drugs and alcohol, causing mental and emotional distress.
High Court’s Decision
The appellants initially approached the Karnataka High Court seeking quashing of the criminal proceedings. The High Court, in its order dated September 15, 2023, partially allowed the petition, quashing proceedings under Sections 504 and 506 of the IPC and Sections 3(1)(r), 3(1)(s), and 3(1)(w) of the SC/ST Act. However, the court refused to quash the criminal proceedings under Section 498-A of IPC and Sections 3 and 4 of the Dowry Prohibition Act, leading the appellants to challenge this decision before the Supreme Court.
Supreme Court’s Observations
The Supreme Court, after hearing arguments from both sides, found the allegations to be vague, lacking specificity, and not supported by prima facie evidence. The court noted that the complainant had admitted that her in-laws resided separately, thereby reducing the likelihood of their direct involvement in any harassment or cruelty.
Citing additional material placed on record, the court took into consideration an earlier ruling by the II Additional Principal Judge, Family Court, Mysuru, which had granted divorce to the husband on August 19, 2023, on grounds of cruelty by the complainant. The Family Court had found the complainant’s allegations regarding dowry and financial support to be false, further reinforcing the appellants’ claim that the criminal proceedings were malicious and frivolous.
Key Excerpts from the Judgment
“Criminal law should not be used as a tool for harassment or vendetta. The allegations in a criminal complaint must be scrutinized with care to ensure that they disclose a prima facie case before subjecting individuals to the rigors of a criminal trial.”
The Supreme Court stressed that while Section 498-A of IPC and the Dowry Prohibition Act are meant to protect women from cruelty and harassment, they should not be misused for settling personal scores or for ulterior motives. The court observed that the complainant had made “manifestly frivolous and meritless allegations”, which did not establish a prima facie case of cruelty or dowry harassment.
Final Verdict
Allowing the appeals, the Supreme Court quashed the criminal proceedings against all the appellants. It held that continuing the trial would amount to an abuse of process of law and a miscarriage of justice.
“Once it has been held that there is no merit or truthfulness to the allegations made, then criminal proceedings on the very same allegations cannot be allowed to continue and propagate misuse of the criminal justice system,” the judgment stated.
