Vague, Omnibus Allegations Cannot Sustain 498-A Prosecution; Bombay HC (Nagpur Bench) Flags ‘Pressure Tactic’ Trend, Quashes FIR

The Nagpur bench of the Bombay High Court has quashed a criminal case registered under Section 498-A IPC against a man and his family members, holding that the allegations of cruelty were vague and unsupported, and warning against a “disturbing pattern” of matrimonial prosecutions being used as a pressure tactic.

Justice Pravin Patil, sitting singly, set aside the FIR lodged by Wardha police on the complaint of the man’s estranged wife, observing that the criminal process cannot be permitted to become a tool for coercion or vendetta in marital disputes.

The Court said it has increasingly noticed that criminal cases under Section 498-A are being initiated with “oblique or collateral motives” during ongoing matrimonial discord or negotiations.

“This Court cannot remain oblivious to the disturbing pattern that has emerged in recent times, wherein matrimonial prosecutions are frequently initiated as a pressure tactic during subsistence of marital disputes and negotiations,” the bench observed.

It stressed that courts are not expected to remain passive in such situations and must examine whether the criminal machinery is being invoked to settle personal scores.

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The bench took note of the tendency to implicate multiple family members, including elderly parents and married sisters, without specific accusations.

It held that indiscriminate arraignment of relatives dilutes the purpose of Section 498-A, which is meant to protect genuine victims of cruelty.

According to the Court, allowing such prosecutions to continue leads to prolonged harassment, social stigma and irreparable prejudice to persons who may ultimately be found uninvolved.

The High Court emphasised that the criminal justice system cannot be reduced to a forum for settling matrimonial disputes on the basis of “vague and embellished accusations.”

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It underscored a constitutional obligation to balance two competing concerns: safeguarding genuine victims of domestic cruelty and protecting innocent persons from vexatious prosecution.

The bench also remarked that many such complaints are filed “in the heat of the moment over trivial issues” and are not bona fide.

On the facts of the case, the Court found that the complainant had failed to substantiate the allegations of cruelty and harassment against her husband and his relatives.

In the absence of specific, credible material, the continuation of criminal proceedings was held to be unjustified.

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Accordingly, the FIR and all consequential proceedings against the husband and his family members were quashed.

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