False Dowry Allegations: Supreme Court Quashes Criminal Proceedings Against Husband

The case of Achin Gupta vs. State of Haryana & Anr. reached the Supreme Court, raising concerns about the misuse of dowry laws and false allegations in matrimonial disputes. The Court examined whether the allegations against the appellant, which led to the registration of an FIR under Sections 323, 406, 498A, and 506 of the IPC, were genuine or merely an act of vendetta by the wife. The Court’s ruling emphasized the need to prevent abuse of legal provisions meant to protect genuine victims of domestic violence.

Background of the Case

The case originated from an FIR filed by the wife, Tanu Gupta, in 2021 at Urban Estate Hisar Police Station. She alleged that her husband, Achin Gupta, and his family members had harassed her for dowry, physically assaulted her, and even controlled her salary when she was working as an Assistant Professor. Additionally, she accused her husband of having an extramarital affair.

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Following an investigation, the police filed a chargesheet against Achin Gupta but dropped proceedings against the other accused family members. When the High Court of Punjab and Haryana refused to quash the chargesheet, the appellant approached the Supreme Court.

Petitioner’s Arguments

The petitioner, Achin Gupta, through his counsel, argued:

• The FIR was filed in 2021, more than 11 months after the complainant left her matrimonial home, and only after she was served a summons in a domestic violence case filed by his mother.
• The allegations were vague and lacked specific incidents or dates, making them unreliable.
• The charges were nothing but a retaliatory action against the divorce petition filed by the appellant in 2019.
• Despite similar allegations against his parents and siblings, the police dropped proceedings against them, indicating that the claims lacked substance.

Respondent’s Arguments

The wife, represented by her counsel, countered that:

• She was subjected to continuous dowry harassment and physical abuse.
• Her in-laws took control of her salary, and she was denied financial independence.
• The husband had an extramarital affair and filed for divorce on false grounds.
• Her complaint was genuine, and she was left with no choice but to approach the police.

State’s Arguments

The State of Haryana supported the police investigation, arguing that:

• The chargesheet against the appellant was filed after a fair investigation.
• The allegations in the FIR warranted trial and could not be quashed at the initial stage.

Supreme Court’s Ruling

The Supreme Court scrutinized the allegations, noting that they were vague, general, and lacked specific details. The Court observed:

• “If a person is made to face a criminal trial on some general and sweeping allegations without bringing on record any specific instances of criminal conduct, it is nothing but abuse of the process of the court.”
• The significant delay in filing the FIR indicated that the complaint was an afterthought, intended to counteract the divorce proceedings.
• The police’s decision to drop charges against other family members weakened the credibility of the accusations.
• Section 498A of the IPC should not be misused to harass husbands and their families based on frivolous claims.

As a result, the Court quashed the criminal proceedings against Achin Gupta and directed the government to re-evaluate the legal framework of Section 498A to prevent its misuse.

Conclusion

This ruling highlights the judiciary’s growing concern over the misuse of dowry laws. While these laws are essential to protect women from genuine abuse, they should not be weaponized to settle personal scores. The Court’s decision reinforces the need for balanced legal protection for both spouses in matrimonial disputes.

Read also: https://judgmentlibrary.com/supreme-court-quashes-criminal-proceedings-key-rulings-on-chargesheets-and-due-process/

Petitioner Name: Achin Gupta.
Respondent Name: State of Haryana & Anr..
Judgment By: Justice J.B. Pardiwala, Justice Manoj Misra.
Place Of Incident: Hisar, Haryana.
Judgment Date: 03-05-2024.

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