Single-judge bench holds that ordinary disputes and marriage incompatibility in marriage do not constitute “cruelty” under Section 498A IPC, emphasising the provision’s targeted scope.
The Karnataka High Court has reiterated that Section 498A of the Indian Penal Code (IPC), which criminalises cruelty by a husband or his relatives towards a wife, is not designed to punish mere marital incompatibility or everyday disputes between spouses. The Court quashed a FIR and ensuing criminal proceedings lodged by a wife against her husband and in-laws, holding that the allegations did not meet the statutory threshold of cruelty under the provision.
Court & Bench
The case is titled ABUZAR AHMED and Others and State of Karnataka and ANR. A single-judge bench of Justice M. Nagaprasanna delivered the order on 9 January 2026 in Criminal Petition No. 7053 of 2024.
Background of the Case
The petitioners, including Abuzar Ahmed, his father, mother and brother-in-law, challenged the registration of a crime based on a complaint by the petitioner’s wife under Sections 498A and 504 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act, 1961.
The couple married on 25 August 2017 and lived in the United States for about six years, during which a child was born. After the complainant returned to India in January 2023, she lodged a complaint alleging harassment by the husband and his family. A look-out circular was issued as part of the investigation, restricting the husband’s travel abroad.
Legal Issue
The principal legal question before the High Court was whether the grievances detailed in the complaint, including dietary restrictions, disagreements over household responsibilities and lifestyle differences, constituted “cruelty” within the meaning of Section 498A IPC, or amounted to normal incidents of marital discord that are not criminal in character.
Court’s Reasoning
After examining the complaint, the Court found that the grievances, even if accepted at face value, merely highlighted marital discord and differences in personal preferences, lacking any conduct so severe as to endanger life, limb, health or mental well-being, or connected to unlawful dowry demands, the core elements envisioned under Section 498A.
Justice Nagaprasanna observed that Section 498A is a targeted provision, intended to address grave cruelty or pernicious conduct, and not a remedy for all matrimonial problems. The Court noted that the continuation of the investigation would serve no purpose other than prolonging harassment, stigmatizing the petitioners, and burdening the courts, especially where allegations lacked substance and were “inherently improbable”.
The bench also took objection to the registration of the FIR without a preliminary inquiry, as mandated by Supreme Court precedents, and the issuance of a look-out circular on the basis of tenuous allegations.
Final Ruling
The High Court allowed the criminal petition and invoked its inherent jurisdiction under Section 482 of the Criminal Procedure Code (CrPC) to quash the FIR and all proceedings arising from it against the petitioners. Justice Nagaprasanna emphasized that permitting the criminal process to continue on such allegations would amount to an abuse of the judicial process.
Practical Implications
- Clarification on Section 498A Scope: The judgment underscores that ordinary marital compatibility issues, including disagreements over household matters or personal lifestyle choices, do not meet the statutory definition of cruelty.
- Emphasis on Preliminary Inquiry: The Court’s critique of registration without preliminary inquiry reinforces the procedural safeguard urged by the Supreme Court in cases involving alleged cruelty or domestic harassment.
- Abuse of Legal Process: The ruling serves as a reminder that criminal provisions should not be used as a dragnet for resolving domestic disputes that fall short of criminality, preventing undue harassment of accused individuals and their families.
The judgment adds clarity on the limited ambit of Section 498A IPC, affirming that only conduct satisfying the high statutory threshold of cruelty, not routine marital friction or incompatibility, warrants criminal sanctions under the provision.
