Supreme Court Quashes 498A IPC Case Filed by Woman Officer Against Husband and In-Laws

Misuse of Legal Provisions Highlighted

The Apex Court expressed strong disapproval of the complainant’s misuse of legal machinery, especially considering her position as a state officer. The Court found it deeply unfortunate that she had arrayed multiple family members, including elderly in-laws and a tailor, as accused without concrete evidence.

In paragraph 13 of the ruling, the Bench observed:

“It is rather unfortunate that the complainant, being an officer of the State, has initiated criminal machinery in such a manner… This growing tendency to misuse legal provisions has time and again been condemned by this Court.”

Background of the Case

The complainant and the accused husband, both serving as Sub-Inspectors with Delhi Police, married on February 28, 1998. Allegations of dowry demands, abuse, and physical assault followed. FIR No. 1098/2002 was registered at PS Malviya Nagar after a delayed complaint in 2002. The allegations included demands for cash, vehicle, and house, along with physical abuse during pregnancy and abandonment.

The Sessions Court discharged the accused due to lack of evidence, time-barred prosecution, and questionable credibility of the complainant. However, the Delhi High Court reversed this decision, stating that being a police officer does not disqualify someone from being a victim.

Supreme Court’s Analysis

The Bench, comprising Hon’ble Justice Satish Chandra Sharma and Hon’ble Justice BV Nagarathna, examined the allegations and evidence in detail. In paragraph 11, it was noted that the allegations were vague and lacked medical evidence, witness testimonies, or any concrete proof.

In paragraph 12, the Court criticized the High Court’s reasoning for reinstating charges solely based on the complainant’s occupation, asserting that judicial reasoning must be grounded in factual evidence.

Timeline of Events

• 1999: Alleged incidents of cruelty including physical assault and dowry demands.
• 2002: Formal complaint filed; FIR registered in December.
• 2004: Charge-sheet filed; charges framed under Section 498A IPC.
• 2008: Sessions Court discharged the accused due to delay and lack of evidence.
• 2024: High Court reversed the discharge; Supreme Court appeal filed.

Supreme Court’s Final Verdict

While noting that the question of limitation under Section 468 CrPC does not apply due to the nature of the complaint, the Court emphasized that the factual matrix did not justify proceeding with trial. Observing that the complainant failed to challenge the final divorce decree and considering the time elapsed since 1999, the Court found no prima facie case made out.

In paragraph 19, the Bench exercised its extraordinary powers under Article 142 to quash FIR No. 1098/2002 and the corresponding charge-sheet, declaring:

“In the interest of justice, and in exercise of our powers under Article 142… we deem it fit and appropriate to quash and set aside the FIR and charge-sheet.”

The appeals were allowed and the case brought to a close.