Supreme Court Slams Vague Allegations: Landmark Acquittal in Dowry Harassment Case

By Abhishek Jat, Advocate

Case Title: Rajesh Chaddha v. State of Uttar Pradesh

Citation: Criminal Appeal No(s). of 2025 [Arising out of SLP (Crl.) Nos. 2353-2354 of 2019]

Bench: Justice Satish Chandra Sharma

Factual Matrix

The Supreme Court addressed an appeal arising from a protracted dowry-related prosecution, where the appellant, Rajesh Chaddha, had been convicted under Section 498A of the Indian Penal Code (IPC) and Section 4 of the Dowry Prohibition Act, 1961. The complainant, Mala Chaddha, had alleged persistent mental and physical harassment for dowry by her husband and in-laws. The prosecution’s case relied primarily on the testimonies of the complainant and her father, with no corroborative medical or documentary evidence to substantiate the allegations of physical cruelty or miscarriage.

Procedural History

• The trial court acquitted the appellant of charges under Sections 323/34 and 506 IPC due to lack of evidence but convicted him under Section 498A IPC and Section 4 of the Dowry Prohibition Act, 1961, sentencing him to two years’ rigorous imprisonment and a fine.
• The conviction was upheld by the Sessions Court and the High Court of Allahabad, both of which found no legal infirmity or perversity in the trial court’s findings.
• The appellant challenged these orders before the Supreme Court, contending that the allegations were vague, unsubstantiated, and motivated, especially as the FIR was lodged after the initiation of divorce proceedings.

Supreme Court’s Analysis

The Supreme Court scrutinized the evidentiary foundation of the prosecution’s case. The Court noted the following critical deficiencies:

• Lack of Specificity: The allegations were generic, lacking precise dates, details, or a consistent timeline of events. The Court emphasized that criminal law requires specific, credible, and timely evidence, not broad or omnibus accusations.
• Absence of Corroboration: There was no independent or medical evidence to support the claims of physical assault or miscarriage. The testimonies of the complainant and her father, while consistent, could not alone sustain a conviction in the absence of corroborative material.
• Finality of Divorce: The marriage had already been dissolved by a decree of divorce, which remained unchallenged, further weakening the prosecution’s case and raising concerns about the bona fides of the complaint.

Legal Principles and Precedents Cited

The Court relied on established jurisprudence regarding Section 498A IPC and the Dowry Prohibition Act, reiterating that:

• Omnibus Allegations Insufficient: Criminal liability cannot be fastened on the basis of sweeping allegations against an entire family without attributing specific roles or acts to individual accused persons.
• Requirement of Proof Beyond Reasonable Doubt: The prosecution must establish cruelty or dowry demand beyond reasonable doubt, supported by cogent evidence.

Key Precedents Discussed:

• Bhagwan Jagannath Markad v. State of Maharashtra [(2016) 10 SCC 537]
• Arun Vyas & Anr. v. Anita Vyas [(1999) 4 SCC 690]
• Surendran v. State of Kerala [(2022) 15 SCC 273]

Judicial Pronouncement

The Supreme Court set aside the conviction, holding that the prosecution failed to discharge its burden of proof. The Court observed:

“The word ‘cruelty’ cannot be used as a weapon. It must be established through facts — not assumption... Continuing the prosecution in the circumstances would amount to harassment and an abuse of process.”

Glossary of Key Legal Terms

• Section 498A IPC: Penal provision addressing cruelty by husband or his relatives towards a married woman.
• Dowry Prohibition Act, 1961: Legislation prohibiting the giving or taking of dowry.
• Omnibus Allegations: Broad, unspecific accusations lacking particularity.
• Corroboration: Additional evidence that confirms or supports a statement, theory, or finding.
• Revisionary Jurisdiction: The power of a higher court to review and correct the decisions of lower courts.

Conclusion

This judgment reinforces the necessity of rigorous evidentiary standards in criminal prosecutions under dowry and cruelty laws. The Supreme Court’s intervention highlights the importance of safeguarding the rights of the accused against unsubstantiated and vague allegations, ensuring that criminal law is not weaponized for collateral purposes. The decision serves as a significant precedent for future cases involving similar factual and legal matrices.

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