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True Colors of a Vile Wife

Tag: CrPC 482 – IPC 498A Quashed

Mohammad Miyan and Ors Vs State of UP on 21 Aug 2018

Posted on July 14, 2024 by ShadesOfKnife

A division bench of the Apex Court held as follows,

Mr. R. K. Das, learned Senior Counsel appearing for the appellants-accused, submits that the prosecution under section 498A of IPC was clearly not tenable in view of the case of the complainant herself that there had been a divorce almost four years before filing of the FIR.
We find much substance in the submission made by Mr. Das, learned Senior Counsel appearing for the appellants-accused. Even in the FIR dated 18.8.2015, the complainant-wife has stated that her divorce had taken place about four years back. It is not possible to accept the contention made by learned counsel appearing on behalf of complainant-wife that she made the statement in ignorance of Sharia law. She is a Headmistress and must be credited with due knowledge of her meritorious status.
In view of her own averment that she was divorced four years ago, we are of the view that the prosecution is not sustainable under section 498A of the IPC and Sections 3/4 of the Dowry Prohibition Act, 1961.
Section 498A of the IPC opens with the words “Whoever, being the husband or the relative of the husband of a woman….” Therefore, where the complainant approaches with a case that there has been a divorce long back i.e. four years ago before filing of the FIR, section 498A of IPC in terms would not be attracted. We accordingly consider it appropriate to quash the prosecution against all the accused persons under section 498A of IPC and Sections 3/4 of the Dowry Prohibition Act, 1961.

Mohammad Miyan Vs State of UP on 21 Aug 2018

Other Sources:

https://indiankanoon.org/doc/150839791/


Index of Quash Judgments is here.

Posted in Supreme Court of India Judgment or Order or Notification | Tagged 2-Judge (Division) Bench Decision CrPC 482 - IPC 498A case Quashed Due To Earlier Divorce CrPC 482 – IPC 498A Quashed Mohammad Miyan Vs State of UP Reportable Judgement or Order | Leave a comment

Mathi Vijaya Lakshmi and Ors Vs State of Telangana and Anr on 03 May 2024

Posted on May 19, 2024 by ShadesOfKnife

A single judge of Telangana HC, held that allegations against accused are vague and unspecific and hence the proceedings against them are quashed.

From Para 6,

6. In view of the rival submissions made by both the counsel, this Court has perused the material available on record. As per the averments of the complaint, petitioners/accused Nos.2 to 5 along with accused No.1 harassed respondent No.2 for want of additional dowry. It is pertinent to note that except the above allegation there are no specific allegations against the petitioners/accused Nos.2 to 5 and there is no allegation to demonstrate that they interfered with the matrimonial disputes between accused No.1 and respondent No.2. Further, the statement of respondent No.2 recorded by the Police under Section 161 of Cr.P.C., shows that when she complained to accused Nos.2 to 5 about the harassment of accused No.1, they supported accused No.1. Except the above said allegation, there are no specific allegations against the petitioner to constitute offence under Section 498-A of IPC and Sections 3, 4 of DP Act.

From Paras 7 and 8,

7. At this stage, it is relevant to note the observations made by the Apex Court in State of Haryana and others vs. Bhajanlal1, whereunder the following categories were illustrated, wherein the extraordinary power under Article 226 of the Constitution of India or the inherent powers under Section 482 Cr.P.C. can be exercised by the High Court to prevent the abuse of process of any Court or otherwise to secure the ends of justice.
8. Further, in Preeti Gupta vs. State of Jharkhand2, the Apex Court observed that the family members who are residing away from accused No.1 cannot be roped into the case. In view thereof, as the petitioners are not residing along with the family of accused No.1, the allegations against them are vague. Therefore, it can be said that category No.1 as extracted above in the case of Bhajanlal (Supra) is relevant to the present case. Therefore, this Court is of the considered view that even if the trial is conducted, no purpose would be served and there are no other specific allegations against the petitioners.

Mathi Vijaya Lakshmi and Ors Vs State of Telangana and Anr on 03 May 2024

Index of Quash judgments is here.

Posted in High Court of Telangana Judgment or Order or Notification | Tagged 1-Judge Bench Decision Absurd Or After Thought Or Baseless Or False Or General Or Inherently Improbable Or Improved Or UnSpecific Or Omnibus Or Vague Allegations CrPC 482 - Quash CrPC 482 – IPC 498A Quashed IPC 498A and 3 and 4 DP Act Combo Alleged Mathi Vijaya Lakshmi and Ors Vs State of Telangana and Anr | Leave a comment

Rakesh Rajput and Anr Vs State of Jharkhand and Anr on 31 Oct 2023

Posted on November 11, 2023 by ShadesOfKnife

A single judge of Jharkhand High Court held the open secret of misuse of 498A IPC.

From Paras 8-12,

8. With the laudable object of punishing cruelty at the hands of husband or his relatives, Section 498-A of the Indian Penal Code was inserted in the statute. There is a phenomenal increase in matrimonial disputes in recent years and it appears that in many cases, the object of Section 498-A of the Indian Penal Code is being misused and the said Section is used as weapon rather than shield by disgruntled wives. The Hon’ble Supreme Court in the case of Arnesh Kumar v. State of Bihar , reported in [(2014) 8 SCC 273], certain guidelines have been issued how to arrest a person against whom matrimonial disputes are there.
9. Such type of cases are being filed in the heat of the moment over trivial issues without proper deliberations and this aspect of the matter has been considered by the Hon’ble Supreme Court in the case of Preeti Gupta v. State of Jharkhand, reported in [(2010) 7 SCC 667].
10. Little matrimonial skirmishes suddenly erupt which often assume erious proportions resulting in commission of heinous crimes in which elders of the family are falsely implicated by the wives. This aspect of the matter has been considered by the Hon’ble Supreme Court in the case of Geeta Mehrotra v. State of U.P. , reported in [(2012) 10 SCC 741].
11. The Hon’ble Supreme Court in the case of K. Subba Rao v. State of Telangana, reported in [(2018) 14 SCC 452] has observed that the Court should be careful in proceeding against the distant relatives in crimes pertaining to matrimonial disputes and dowry deaths.
12. The above line of judgments of the Hon’ble Supreme Court clearly suggest that how Section 498-A of the Indian Penal Code is being misused nowadays.

Rakesh Rajput and Anr Vs State of Jharkhand and Anr on 31 Oct 2023

Index of Quash judgments here.

Posted in High Court of Jharkhand Judgment or Order or Notification | Tagged 1-Judge Bench Decision Catena of Landmark Judgments Referred/Cited to CrPC 482 – IPC 498A Quashed Discourage Roping In All Relatives Of In-Laws Or Distant Relatives Legal Terrorism Rakesh Rajput and Anr Vs State of Jharkhand and Anr | Leave a comment

A. Subash Babu Vs State of A.P. and Anr on 26 Feb 2010

Posted on March 16, 2021 by ShadesOfKnife

AP High Court only quashed 498A IPC but not 494 IPC.

A. Subash Babu Vs State of A.P. and Anr on 26 Feb 2010

Citation : [2010 ALT CRI 2 56], [2010 CRI LJ 2523], [2010 SCC ONLINE AP 148], [2010 ALD CRI 1 562]

Other Sources :

https://www.casemine.com/judgement/in/56b48d37607dba348fff1e09

https://www.legitquest.com/case/a-subash-babu-v-state-of-ap-rep-by-public-prosecutor-another/13654


This judgment was set aside by Supreme Court here.

Posted in High Court of Andhra Pradesh Judgment or Order or Notification | Tagged 1-Judge Bench Decision A.Subash Babu Vs State of A.P. and Anr CrPC 482 – IPC 498A Quashed Overruled Judgment | Leave a comment

Shabnam Sheikh Vs State of Maharashtra on 15 Oct 2020

Posted on October 21, 2020 by ShadesOfKnife

Vagua allegations don’t take fake cases far. Bombay HS quashed the fake case of 498A IPC against the relatively.

From Para 14,

14. Nowadays, it has become a tendency to make vague and omnibus allegations, against every member of the family of the husband, implicating everybody under Section 498-A of the Indian Penal Code. Hence, it has become necessary for the Courts to carefully scrutinize the allegations and to find out if the allegations made really constitute an offence and meet the requirements of the law at least prima facie.

 

Shabnam Sheikh Vs State of Maharashtra on 15 Oct 2020
Posted in High Court of Bombay Judgment or Order or Notification | Tagged 2-Judge (Division) Bench Decision Absurd Or After Thought Or Baseless Or False Or General Or Inherently Improbable Or Improved Or UnSpecific Or Omnibus Or Vague Allegations Catena of Landmark Judgments Referred/Cited to CrPC 482 – FIR Quashed CrPC 482 – IPC 498A Quashed Discourage Roping In All Relatives Of In-Laws Or Distant Relatives IPC 498a - Not Made Out Against Parents or Relatives Legal Terrorism Shabnam Sheikh Vs State of Maharashtra | Leave a comment

Kamlesh Kalra Vs Shilpika Kalra and Ors on 24 April 2020

Posted on August 24, 2020 by ShadesOfKnife

Daughter-in-law launched a pressure tactic (supreme court’s words) against her in-laws and husband but had to eat dirt in the end. Since the complaint was filed after more than limitation period of 3 years, the 498A case was quashed.

Trivia: No launching of criminal proceedings for filing a false case.

Kamlesh Kalra Vs Shilpika Kalra and Ors on 24 April 2020

Citations :

Other Sources :

 

Posted in Supreme Court of India Judgment or Order or Notification | Tagged CrPC 482 – IPC 498A Quashed IPC 406 - Not Made Out IPC 498A - 3 Years Limitation Kamlesh Kalra Vs Shilpika Kalra and Ors Legal Terrorism | Leave a comment

Amarjit Kaur and Ors Vs Jaswinder Kaur and Ors on 15 May 2020

Posted on May 18, 2020 by ShadesOfKnife

Taking cue from Geeta Mehrotra judgment here, Punjab High Court has quashed proceedings on relatives living far away in Canada taking a ground that no specific allegation are in the complaint.

Amarjit Kaur and Ors Vs Jaswinder Kaur and Ors on 15 May 2020

Citations: [2]

Other Source links: https://indiankanoon.org/doc/12422589/

Posted in High Court of Punjab & Haryana Judgment or Order or Notification | Tagged 1-Judge Bench Decision Amarjit Kaur and Ors Vs Jaswinder Kaur and Ors CrPC 482 - Quash CrPC 482 - Saving of inherent powers of High Court CrPC 482 – Criminal Proceeding Quashed CrPC 482 – IPC 498A Quashed Discourage Roping In All Relatives Of In-Laws Or Distant Relatives Geeta Mehrotra and Anr Vs State Of U.P. and Anr IPC 498a - Not Made Out Against Parents or Relatives Legal Terrorism Order Quashed | Leave a comment

Shyamlal Devda and Ors Vs Parimala on 02 April 2019

Posted on January 23, 2020 by ShadesOfKnife

Karnataka High Court has quashed this 498A IPC case on 11 of the accused relatives of the Husband since the complaint is full of junk vague and non-specific allegations.

Shyamlal Devda and Ors Vs Parimala on 02 April 2019

The Supreme Court had crushed another false DV case by this liar and quashed it on 11 of the accused relatives of the Husband here.


Citations: [

Other Source links: https://www.casemine.com/judgement/in/5d4be4364a9326071f285522


The Index of these cases is here.

Posted in High Court of Karnataka Judgment or Order or Notification | Tagged CrPC 482 – IPC 498A Quashed Discourage Roping In All Relatives Of In-Laws Or Distant Relatives DP Act 3 - Not Made Out DP Act 4 - Not Made Out DP Act 6 - Not Made Out Shyamlal Devda and Ors Vs Parimala Work-In-Progress Article | Leave a comment

Korimerla Videesha Vs State of A.P. and Anr on 12 October 2018

Posted on December 12, 2019 by ShadesOfKnife

In a rare act, Justice Satyanarayan Murthy has given a Quash order in a false 498A IPC case. He also invoked AP Dowry Prohibition Rule 1998 which are available here.

Korimerla Videesha Vs State of A.P. and Anr on 12 October, 2018

Citations:

Other Source Links: https://indiankanoon.org/doc/114175976/

Posted in High Court of Andhra Pradesh Judgment or Order or Notification | Tagged A.P. Dowry Prohibition Rules 1998 Absurd Or After Thought Or Baseless Or False Or General Or Inherently Improbable Or Improved Or UnSpecific Or Omnibus Or Vague Allegations Catena of Landmark Judgments Referred/Cited to CrPC 482 – IPC 498A Quashed Dowry Prohibition Act 1961 DP Act 3 - Not Made Out DP Act 4 - Not Made Out IPC 498a - Not Made Out IPC 498A and 3 and 4 DP Act Combo Alleged Korimerla Videesha Vs State of A.P. and Anr Misuse of Section 498A of IPC Sandeep Pamarati

Puttalakshmi Vs State of Karnataka and Anr on 09 November, 2018

Posted on January 2, 2019 by ShadesOfKnife

Hon’ble Karnataka High Court, based on Preeti Gupta judgment here, held that the Dowry proceedings (u/s 498A IPC) against Mother-in-law are false and motivated, hence quashed same. God know if any sou moto perjury proceedings initiated or not on the false-case filing daughter-in-law!!

Smt.Puttalakshmi Vs State of Karnataka and Anr on 09 November, 2018

Citations: [2018 SCC OnLine Kar 1820],

Indiankanoon.org or Casemine link: https://indiankanoon.org/doc/162793182/ or https://www.casemine.com/judgement/in/5bebe8c39eff4376dc966c50


Reproduced in accordance with Section 52(q) of the Copyright Act 1957 (India) from main.sci.gov.in/judgments, judis.nic.in, lobis.nic.in, indiacode.nic.in and other Indian High Court and District Court Websites such as ecourts.gov.in

Posted in High Court of Karnataka Judgment or Order or Notification | Tagged CrPC 482 – IPC 498A Quashed IPC 498a - Not Made Out Against Parents or Relatives Smt.Puttalakshmi Vs State of Karnataka and Anr | Leave a comment

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