In a significant ruling, the Allahabad High Court has quashed criminal proceedings initiated under Sections 498-A, 504, 506, 509 of the Indian Penal Code (IPC) and sections 3/4 of the Dowry Prohibition (DP) Act. The court ruled that general and vague allegations made in matrimonial disputes do not justify prosecution unless specific instances are substantiated by evidence. This decision came in response to an application filed by Pranjal Shukla and others, challenging the proceedings initiated against them based on an FIR alleging dowry harassment, cruelty, and unnatural sexual demands. The court emphasized that matrimonial disputes must not be used as a tool for malicious prosecution.
Background of the Case:
In Pranjal Shukla & Others vs. State of U.P. and Another (Application U/S 482 No. 27067 of 2019), the applicants sought the quashing of criminal proceedings initiated against them under various sections of the Indian Penal Code (IPC) and the Dowry Prohibition (DP) Act. The case was based on an FIR lodged by Meesha Shukla, wife of the applicant Pranjal Shukla, alleging dowry harassment, cruelty, and unnatural sexual demands made by her husband and in-laws. The complaint also included allegations of physical abuse, assault, and coercion for dowry during her stay in both India and Singapore.
The case crime number 83 of 2018, registered at Mahila Thana, Gautam Buddh Nagar, formed the basis for the criminal charges. Meesha’s father, the opposite party, further accused Pranjal Shukla and his family of threatening his daughter’s life, demanding additional money, and harassing her for dowry.
The applicants filed for quashing of the charge-sheet, contending that the FIR and subsequent investigation were based on vague and general allegations without specific instances or details of dowry demands.
Important Legal Issues Involved:
1. Validity of General and Vague Allegations: The central issue was whether the allegations in the FIR constituted sufficient grounds for prosecution under sections 498-A (cruelty), 504 (intentional insult), 506 (criminal intimidation), 509 (insult to the modesty of a woman) of the IPC and sections 3/4 of the DP Act.
2. Abuse of Process of Law: The applicants argued that the case was a malicious prosecution, relying on multiple precedents where courts held that vague and omnibus allegations could not justify criminal trials.
3. Matrimonial Disputes and Dowry Allegations: The court also examined whether the complaints made by the wife stemmed from a genuine dowry-related issue or were exaggerated claims arising out of personal disputes.
Court’s Decision:
Justice Anish Kumar Gupta of the Allahabad High Court quashed the criminal proceedings, including the charge-sheet and cognizance/summoning order, finding that the FIR contained no specific allegations of dowry demands or cruelty. The court relied on key judgments from the Supreme Court, including Geeta Mehrotra vs. State of U.P. (2012) and Kahkashan Kausar vs. State of Bihar (2022), where it was observed that sweeping allegations in matrimonial disputes should not lead to criminal prosecutions unless specific evidence supports the claims.
The court observed:
“There is no avernment with regard to any specific demand of dowry made by any specific person except general and vague allegations.”
The court further emphasized that matrimonial disputes often involve personal issues, and criminalizing such matters without substantial evidence could lead to injustice. Quoting from previous judgments, the court noted:
“If man would not demand sexual favour from his own wife and vice-versa, where they will go to satisfy their physical sexual urges in a morally civilized society.”
The court found that the allegations related more to sexual incompatibility and personal disputes rather than any actual cruelty or dowry demands.
Important Observations:
The High Court concluded that the allegations made by the wife were not sufficient to sustain a criminal case, stating:
“By no stretch of imagination it can be said to be an offence of cruelty in terms of section 498-A I.P.C.”
The judgment quashed the entire proceedings of Case No. 395 of 2019 and relieved the applicants from further prosecution, reinforcing the judiciary’s stance against the misuse of Section 498-A for settling personal scores in matrimonial disputes.
