Woman's in-laws asking her to adjust in marriage is not cruelty: Supreme Court

The Supreme Court recently held that a man's relatives cannot be prosecuted for marital cruelty merely because they advised his wife to either “adjust” in the marriage or return to her parental home [Arti Mehta v. State of Madhya Pradesh].

A Bench of Justices Sanjay Karol and N Kotiswar Singh added that although such conduct may be morally questionable, it cannot automatically be elevated to the status of a criminal act.

The Court made the observation while quashing cruelty, domestic violence and dowry harassment-related criminal proceedings initiated against the in-laws of a woman in a matrimonial dispute from Madhya Pradesh.

The Court found that the allegations against the husband’s relatives were vague, omnibus and unsupported by specific material.

It was further observed that no distinct incident, overt act, unlawful dowry demand, physical cruelty or active participation had been specifically attributed to any of the woman's in-laws individually.

"Mere allegations that family members 'supported' the husband, failed to intervene, or advised the complainant to adjust in the matrimonial relationship, without anything further, would not ipso facto attract criminal liability. There may indeed be situations where certain relatives remain passive spectators or fail to come to the aid of the complainant; however, such conduct, though morally questionable, cannot automatically be elevated to the status of criminal culpability unless the surrounding circumstances clearly disclose their active complicity or participation in the alleged offences," the Court said in its judgment delivered on May 25.

The Bench added that while safeguarding domestic violence victims is important, courts must ensure that criminal law is not indiscriminately invoked against every member of a man's family in matrimonial disputes without a clear factual foundation.

The Court was hearing appeals filed by the a man's sister-in-law and other relatives challenging the Madhya Pradesh High Court's refusal to quash criminal proceedings initiated against them in a matrimonial dispute.

The case arose from allegations made by a woman against her husband and his family members after her marriage in 2019.

The relatives implicated in the case included the husband’s mother, brother, sister and sister-in-law. The woman alleged that her husband and in-laws harassed her for dowry, subjected her to mental and physical cruelty and repeatedly pressured her to bring money from her parental home.

Based on her complaint, the police registered a First Information Report (FIR) under Sections 498A (cruelty) and 34 (common intention) of the Indian Penal Code (IPC), and Sections 3 (dowry) and 4 (dowry demand) of the Dowry Prohibition (DV) Act against the husband and his relatives.

The woman also separately initiated domestic violence proceedings against the husband and his relatives, alleging harassment, abuse and dowry demands. A magistrate court in Guna took cognisance of the complaint and initiated criminal proceedings against all the accused family members.

The husband’s relatives then approached the Madhya Pradesh High Court seeking the quashing of both the criminal case and the domestic violence proceedings. However, the High Court refused to quash proceedings against them.

Aggrieved by this, the husband’s sister and other relatives approached the Supreme Court.

The top court noted that most of the allegations of assault, threats, neglect and harassment made by the wife had been directed against the husband. It further noted that the accusations against the in-laws remained generalised, omnibus and lacking in material particulars.

“No independent or specific role has been attributed to any of the present appellants so as to disclose prima facie commission of offences under Sections 498A/34 IPC or Sections 3 and 4 of the Dowry Prohibition Act,” the Bench stated.

The Court also took note of the wife’s own pleadings showing that she primarily lived with her husband at Sheopur in Madhya Pradesh, while the in-laws resided separately at Shivpuri. The Court said this weakened the allegations of continuous harassment by the relatives.

The Bench also noted that during the pendency of the proceedings, the marriage between the complainant (wife) and her husband had already been dissolved by a decree of divorce passed by the  Family Court.

The Court observed that in such circumstances, continuation of the domestic violence proceedings against the in-laws in the absence of specific and substantiated allegations against them would serve no useful purpose.

“It is not uncommon that when matrimonial relationships deteriorate, allegations are made in the heat of emotional turmoil and bitterness, often resulting in the entire family of the spouse being drawn into criminal litigation,” the Court added.

However, criminal law cannot be permitted to become an instrument for venting personal grievances or settling familial scores, the Court warned.

The Bench cautioned that courts must exercise a heightened degree of judicial scrutiny before permitting criminal prosecution against relatives who are implicated merely because of their relationship with a spouse.

[Read Judgment]