This is the landmark judgment from Delhi High Court which held that “A mother who is being maltreated and harassed by her son would be an “aggrieved person”. If the said harassment is caused through the female relative of the son i.e. his wife, the said female relative will fall within the ambit of the “respondent‟. This phenomenon of the daughters-in-law harassing their mothers-in-law especially who are dependent is not uncommon in the Indian society.”
From Paras 9 and 10,
Kusum Lata Sharma Vs State & Anr. on 2 September, 20119. As a matter of fact, para ‘4(i)’ clarifies that even those women who are sisters, widows, mothers, single woman or living with the abuser are entitled to legal protection under the proposed legislation. A mother who is being maltreated and harassed by her son would be an “aggrieved person”. If the said harassment is caused through the female relative of the son i.e. his wife, the said female relative will fall within the ambit of the ‘respondent’. This phenomenon of the daughters-in-law harassing their mothers-in-law especially who are dependent is not uncommon in the Indian society.
10. In view of the authoritative pronouncement of the Hon’ble Supreme Court, para ‘4’ of the Statement of Objects and Reasons cannot be stated to have excluded a female relative of the male partner or a respondent and thus, a mother-in-law being an “aggrieved person” can file a complaint against the daughter-in-law as a respondent.
Citations : [2011 DMC 3 1], [2011 CRIMES 4 548], [2011 DLT 181 775], [2011 DRJ 126 298], [2011 ILR SUPP DELHI 4 435], [2012 RCR CRIMINAL 1 924], [2011 SCC ONLINE DEL 3710], [2011 AIC 106 846], [2011 AD DELHI 6 576]
Other Sources :
https://indiankanoon.org/doc/1272794/
https://www.casemine.com/judgement/in/56090db1e4b014971117a40b