B. V. NAGARATHNA, SATISH CHANDRA SHARMA
Rajesh Chaddha – Appellant
Versus
State of Uttar Pradesh – Respondent
JUDGMENT :
SATISH CHANDRA SHARMA, J.
1. Leave granted.
2. These Appeals by special leave are directed against Order dt.14.11.2018 passed by the High Court of Allahabad in Criminal Revision No. 612/2004 filed against the judgment and order dt. 18.11.2004 passed by the Additional Sessions Judge, Lucknow [hereinafter “Sessions Court”] whereby the Criminal Appeal No. 88/2004 filed by the Appellant was dismissed and the conviction of the Appellant under Section 498A of the Indian Penal Code (hereinafter “IPC” & Section 4 of the Dowry Prohibition Act, 1961 [hereinafter “DP Act, 1961”] vide Judgment dt. 28.08.2004 passed by the Chief Judicial Magistrate, Lucknow [hereinafter “Magistrate”] was upheld. The Order dt. 28.11.2018 dismissing the recall application against the said Order dt.14.11.2018 is also under challenge before this Court.
3. The captioned Appeal arises out of Case Crime No. 60/1999 lodged by the PS Women Police Station, Lucknow under Sections 498A, 323, 506 IPC & Sections 3 & 4 of the D.P. Act, 1961, on the basis of a Complaint dt. 20.12.1999 filed by the Complainant wife, against the Appellant husband and her in-laws alleging mental and physical torture for not bringing enough
Yashodeep Bisanrao Vadode VS State of Maharashtra - 2024 8 Supreme 361: State of Jharkhand, (2010) 7 SCC 667 - Cited positively in Paritosh Kumar Ghosh VS State of West Bengal - 2025 0 Supreme(Cal) 56 as holding "that the courts have to be extremely careful and cautious in dealing", indicating it is followed or relied upon for caution in 498A cases.
Ghanshyam Soni VS State (Govt. of NCT of Delhi) - 2025 5 Supreme 413: State of Uttar Pradesh, 2025 INSC 671 - Referenced alongside other cases in Ghanshyam Soni VS State (Govt. of NCT of Delhi) - 2025 5 Supreme 413 and SAROJINI vs STATE OF KERALA - 2026 Supreme(Online)(Ker) 16667 as "Rajesh Chaddha vs. State of Uttar Pradesh [AIR 2025 SC 2836]", suggesting reliance in matrimonial cruelty arguments.
SAROJINI vs STATE OF KERALA - 2026 Supreme(Online)(Ker) 16667: State of Bihar and Ors [(2022) 6 SCC 599] - Explicitly "relied on by the learned Amicus Curiae in support of the argument" in its own snippet, indicating positive treatment and reliance.
Paritosh Kumar Ghosh VS State of West Bengal - 2025 0 Supreme(Cal) 56: Dara Lakshmi Narayana & Ors. vs State of Telangana & Anr. - Cites State of Jharkhand (2010) 7 SCC 667 positively but no explicit treatment keyword; neutral reference in context of 498A amendments.
Mali Subbiah Son Of Late Mahalingam Sidhambaram vs State Of Karnataka - 2025 0 Supreme(Kar) 707: Rajesh Chaddha vs. State of Uttar Pradesh – Cited as "Recently, in the case of Rajesh Chaddha vs." in context of specific allegations under 498A; appears as recent precedent without negative treatment.
State of Uttar Pradesh VS Anurudh - 2026 0 Supreme(SC) 46: Rajesh Chaddha v. ... The State of Uttar Pradesh - Referenced as "Amongst numerous examples, we may only refer to Rajesh Chaddha v.", indicating it is listed as an example in a legal challenge, neutral citation.
Dara Lakshmi Narayana VS State of Telangana - 2025 1 Supreme 726: General principle on misuse of Section 498A - Cited in context warning against misuse but no indication of its own treatment; appears as supporting authority.
Surendran VS State of Kerala - 2022 5 Supreme 303: Dying declaration case - Discusses admissibility under Section 32(1) Evidence Act for 498A; no treatment indicators, neutral reference.
Arun Vyas VS Anita Vyas - 1999 5 Supreme 458: Chapter XXXVI Cr.P.C. object - States protective purpose against vexatious prosecutions; no treatment indicators, neutral.
Bhagwan Jagannath Markad VS State of Maharashtra - 2017 1 Supreme 129: General evidentiary principles - Lists principles like burden of proof, "falsus in uno" non-application; no treatment indicators, appears as cited authority.
Aluri Venkata Ramana VS Aluri Thirupathi Rao - 2024 0 Supreme(SC) 1369: State of Bihar - Fragmentary reference ("State of Bihar"); no context or treatment indicators provided, making treatment entirely unclear.
Sri Subhash Hazarika @ Dhan Hazarika, S/O Sri Hanhiram Hazarika vs State Of Assam, Rep. By The Addl. P. P. - 2025 0 Supreme(Gau) 905: The State of Assam & Anr. ... State - Highly fragmentary ("The State of Assam & Anr. ... State"); lacks sufficient details for any treatment analysis.
Ghanshyam Soni VS State (Govt. of NCT of Delhi) - 2025 5 Supreme 413: State of Gujarat, 2024 INSC 960 - Brief mention alongside other cases ("State of Gujarat, 2024 INSC 960 and Rajesh Chaddha"); no explicit treatment keyword or context, ambiguous reliance.
Cruelty and dowry offences – A cursory or plausible view cannot be conclusive proof to determine guilt of an individual under Section 498A and Section 4 of D.P. Act, 1961 – Term “cruelty” is subject ....
(1) Cruelty – Term “cruelty” cannot be established without specific instances – Mere general allegations of harassment without pointing out specifics against such persons would not be sufficient to c....
Vague allegations in matrimonial disputes cannot sustain criminal prosecution; specificity is required to prevent misuse of legal provisions.
Cruelty and dowry offences – Criminal law must not be permitted to degenerate into instrument of oppression or personal vengeance.
Vague or generalized allegations in matrimonial disputes do not support criminal proceedings under IPC and Dowry Prohibition Act, necessitating specific instances for valid charges.
Cruelty under Section 498A IPC is defined independently of any dowry demand; physical and mental abuse constitute sufficient grounds for charges under this section.
Vague and generalized allegations in matrimonial disputes cannot sustain criminal prosecution under Section 498A IPC, emphasizing the need for specific details to prevent misuse of legal provisions.
Section 498A of IPC reads as husband or relative of husband of a woman subjecting her to cruelty.
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