In-Laws Cannot Face 498A Case Merely For Asking Wife To “Adjust”, Mere Advice Not Criminal Offence: Supreme Court

In Arti Mehta & Ors. versus The State of Madhya Pradesh & Anr., the Supreme Court has ruled that in-laws cannot be prosecuted in matrimonial disputes merely because they advised the wife to “adjust” or failed to stop disputes between the couple. The Court quashed criminal proceedings under Section 498A IPC, the Dowry Prohibition Act, and the Domestic Violence Act against the husband’s relatives.

A Bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh held that vague and omnibus allegations without specific overt acts are insufficient to continue criminal prosecution against relatives of the husband. The Court stressed that mere family association cannot automatically lead to criminal liability.

The dispute arose after the complainant-wife lodged an FIR in January 2023 in Madhya Pradesh alleging dowry harassment, cruelty, and domestic violence against her husband and his family members. She claimed that cash, jewellery, and household articles were given at the time of marriage and that additional monetary demands were later made.

The woman also initiated proceedings under the Domestic Violence Act alleging mental harassment, surveillance through hidden cameras, restrictions on movement, and threats involving a licensed firearm. However, the allegations against the in-laws mainly revolved around claims that they supported the husband or did not intervene in the marital conflict.

The Madhya Pradesh High Court had earlier refused to quash the proceedings, observing that prima facie allegations existed. Challenging this order, the in-laws approached the Supreme Court.

Allowing the appeals, the Supreme Court found that the complaint lacked any clear allegations showing active participation of the in-laws in acts of cruelty or dowry harassment. The Court observed that prosecution in matrimonial disputes must be based on distinct and specific allegations against each accused person.

The Bench stated that allegations such as asking the complainant to adjust in the marriage or remaining passive spectators may appear morally questionable but cannot automatically amount to criminal conduct. The Court clarified that criminal law cannot be used as a tool to settle personal or family disputes without a proper legal foundation.

The judgment also highlighted the increasing tendency to implicate the entire family of the spouse during matrimonial conflicts. The Court observed that when relationships deteriorate, allegations are often made in emotional circumstances, leading to unnecessary criminal litigation against relatives.

The Court further noted that judges must exercise greater caution before allowing criminal proceedings against family members solely because of their relationship with the husband. According to the Bench, criminal prosecution should continue only where there is prima facie material showing active complicity in the alleged offences.

Another important factor considered by the Court was that the marriage between the parties had already been dissolved by a competent Family Court. In view of this development and the absence of specific allegations, the Court held that continuing Domestic Violence Act proceedings against the in-laws would serve no useful purpose.

As a result, the Supreme Court quashed all pending criminal proceedings against the husband’s relatives while clarifying that the complainant remains free to pursue remedies available against the husband in accordance with law.