Supreme Court Raises Concerns Over Misuse of Section 498A IPC in Matrimonial Disputes

The Supreme Court reiterated its concern over the misuse of Section 498A of the Indian Penal Code (IPC) during the hearing of a matrimonial dispute filed just one-and-a-half months after marriage. Justice BV Nagarathna noted that the mother-in-law and husband are increasingly wary of wives due to false complaints.

She described Section 498A as "very draconian and misused," likening it to "squeezing lemon on a relationship." The Court has quashed several such complaints but clarified that not every case is false. Ultimately, the Court directed the parties to undergo mediation to resolve their differences amicably.

Judicial Caution on Section 498A Misuse

Over the past year, the Court has consistently raised concerns about the misuse of Section 498A IPC (now Sections 86 of the Bharatiya Nyaya Sanhita, 2023):

• In May 2024, a bench of Justices JB Pardiwala and Manoj Misra suggested that Parliament reconsider Sections 85 and 86 of the Bharatiya Nyaya Sanhita, as they were a verbatim reproduction of Section 498A and its explanation.

• Earlier this week, Justices Nagarathna and Mahadevan quashed a cruelty and dowry case against a woman’s brother-in-law due to vague and general allegations, emphasizing careful scrutiny to avoid abuse of process.

Supreme Court Upholds Constitutionality But Acknowledges Potential Misuse

In April 2025, a bench of Justices Surya Kant and N Kotiswar upheld the constitutionality of Section 498A, observing that potential misuse alone cannot invalidate the provision. The Court acknowledged instances of misuse but emphasized that for every false case, there are hundreds of genuine cases where Section 498A protects victims of domestic violence.

Judicial Warnings Against Overreach and Abuse of Process

Several rulings led by Justice Nagarathna have criticized the tendency to misuse Section 498A:

• In December 2024, Justices Nagarathna and N Kotiswar Singh cautioned against implicating all members of a husband’s family in domestic cruelty cases, criticizing the provision's misuse as a tool for personal vendetta.

• In the same month, another bench with Justice Nagarathna and Justice Pankaj Mithal warned that Section 498A is sometimes bundled with Sections 376 (rape), 377 (unnatural sex), and 506 (criminal intimidation) as a "combined package" to pressure husbands and their families. The Court advised women not to abuse protective laws.

• In February 2025, Justices Nagarathna and N Kotiswar Singh quashed charges of cruelty, dowry demand, and domestic violence, noting that criminal laws invoked without specific allegations or credible material can cause disastrous family consequences.

• In June 2025, Justices Nagarathna and Satish Chandra Sharma quashed FIR and charges under Section 498A citing vague and omnibus allegations, stressing protection for genuine victims and warning against prosecuting distant relatives indiscriminately.

Acquittal Highlighting Vague Allegations and Malicious Framing

In May 2025, the same bench acquitted a man charged under Section 498A IPC and Section 4 of the Dowry Prohibition Act, 1961. The Court found the allegations vague, lacking specifics, and maliciously framed to implicate aged parents and distant relatives. It noted that such overreach undermines the credibility of complaints and defeats the purpose of protective laws.

Judicial Balance: Protecting Genuine Victims While Preventing Misuse

Throughout these rulings, the Supreme Court has maintained a balanced stance urging sensitivity in genuine cruelty cases while firmly cautioning against the misuse of legal provisions meant for protection.