Introduction
The Supreme Court of India has held that a husband sending money to his parents and asking his wife to maintain household expense records does not amount to cruelty under Section 498A of the Indian Penal Code. The Court quashed the criminal proceedings against the husband and his family members. The ruling draws a clear line between genuine cruelty and routine marital disagreements. It also reinforces judicial caution against the misuse of criminal law in matrimonial disputes.
Facts of the Case
The parties married in December 2016. Both worked as software engineers and lived in the United States after marriage. Their son was born in April 2019. Due to matrimonial differences, the wife returned to India with the child in August 2019.
In January 2022, the husband issued a legal notice seeking restitution of conjugal rights. Soon after, the wife lodged an FIR against the husband, his parents, and other relatives. She alleged offences under Section 498A IPC and the Dowry Prohibition Act.
The wife claimed that the husband sent part of his income to his parents and brother. She alleged that he forced her to maintain an Excel sheet of daily household expenses. She also accused him of neglecting her during pregnancy and making remarks about her weight after childbirth. According to her, these acts amounted to mental cruelty and dowry harassment.
The Telangana High Court declined to quash the FIR. The husband then approached the Supreme Court challenging the continuation of criminal proceedings.
What the Supreme Court Says
A bench comprising Justice B.V. Nagarathna and Justice R. Mahadevan allowed the appeal. The Court held that sending money to parents or other family members is a personal financial decision. Such conduct does not constitute cruelty or dowry demand in the absence of coercion or unlawful pressure.
The Court further ruled that asking a spouse to keep track of household expenses cannot be treated as cruelty under Section 498A. The judges observed that maintaining financial records is a common practice and does not, by itself, cause mental or physical harm.
The Court clarified that mere financial control or dominance, without concrete evidence of abuse, does not meet the legal threshold of cruelty. Allegations regarding lack of care during pregnancy or comments on physical appearance, even if assumed to be true, reflect ordinary marital discord. They do not amount to criminal conduct under Section 498A.
The bench emphasized that the provision requires specific and serious acts that cause grave mental or physical suffering. Vague and generalized allegations cannot justify criminal prosecution. The Court concluded that the complaint was based on normal wear and tear of married life and did not disclose any offence.
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Implications of the Judgment
The judgment reinforces safeguards against the misuse of Section 498A. It reminds courts to carefully examine allegations before allowing criminal trials in matrimonial disputes. Routine disagreements, financial arrangements, or household management issues cannot be criminalized.
The ruling provides clarity to families facing false or exaggerated complaints. It reassures that lawful financial support to parents or requesting transparency in expenses is not an offence. At the same time, the judgment does not dilute protection for genuine victims of cruelty.
Most importantly, the decision underscores that criminal law must rest on clear facts and evidence. Matrimonial conflicts should not automatically lead to criminal prosecution unless the statutory requirements of cruelty are clearly met.
