DARA LAKSHMI NARAYANA vs STATE OF TELANGANA (Supreme Court)

The Supreme Court in DARA LAKSHMI NARAYANA vs STATE OF TELANGANA CRIMINAL APPEAL NO. OF 2024 (Arising out of Special Leave Petition (Criminal) No.16239 of 2024) dismissed a case under Section 498-A IPC, which deals with cruelty, aimed at a husband and his in-laws. The Court raised concerns over the tendency to drag all of a husband’s family members into domestic disputes. There’s a worrying pattern emerging where laws like Section 498-A IPC are misused for personal vendettas against husbands and their families. Just last month, the Court urged other courts to be careful about involving distant relatives in such cases when a wife claims domestic cruelty.

Justices B.V. Nagarathna and N. Kotiswar Singh pointed out that Section 498-A IPC is often used as a legal tool for wives or their relatives to take revenge on husbands and their families. This happens without a proper understanding of the law’s purpose, which is to protect women from cruelty by their husbands and their families, and to ensure fast government intervention.

The Court noted that while the amendment for Section 498-A aimed to protect women from cruelty related to dowry, increasing marital disputes across the country have led some to misuse the law. When vague allegations are made during these conflicts without proper checks, it can lead to the misuse of legal processes and give way to coercive tactics by wives or their families. There are instances where a wife might invoke Section 498-A against her husband and his family to force them to meet unreasonable demands.

In a case the Court reviewed, a husband and his in-laws appealed against a Telangana High Court decision that refused to dismiss a domestic cruelty case filed by the wife after the husband sought a divorce. The Court criticized this approach, emphasizing that the law was designed to protect women facing cruelty due to unlawful demands like dowry. In this instance, however, the wife seemed to be misusing the law in response to her husband’s divorce petition.

The Court stressed that it is not suggesting women who face genuine cruelty should stay silent or refrain from seeking justice. The concern lies with cases like the one at hand, where a complaint under Section 498-A was filed strictly as retaliation against a divorce petition. The aim of the law is to safeguard women from real harm, but misuse can occur, as it did in this case. Ultimately, the Court ruled that the High Court erred by not dismissing the FIR against the husband and his in-laws, resulting in the quashing of the case against them.