SC: Do Not Indiscriminately Criminalize All Family Members in Domestic Violence Cases

In a significant judgment, the Supreme Court of India, on January 07, 2025, set aside criminal proceedings under Section 498A IPC, Section 506 IPC, and Sections 3 and 4 of the Dowry Prohibition Act, 1961, against certain in-laws of the complainant, emphasizing that criminal laws should not be invoked in family disputes without specific allegations and credible supporting materials.

The bench, comprising Justice B.V. Nagarathna and Justice Nongmeikapam Kotiswar Singh, observed that courts must exercise circumspection and judiciousness while dealing with cases where family relationships are sought to be brought under criminal proceedings, as indiscriminate implication can rupture family bonds.

The case involved Geddam Jhansi & Anr. v. The State of Telangana & Ors., where the appellants, who were distant relatives of the complainant's husband, had challenged the High Court’s refusal to quash the proceedings against them. The Supreme Court, upon analyzing the evidence, ruled that no prima facie case was made against them and accordingly quashed the charges.

Background of the Case

• The appellants challenged the criminal proceedings initiated against them under:
  • Section 498A IPC (Cruelty by husband or relatives)
  • Section 506 IPC (Criminal intimidation)
  • Sections 3 and 4 of the Dowry Prohibition Act, 1961 (Dowry demand)
• The High Court had previously ruled that a prima facie case existed against them, refusing to quash the proceedings.
• Aggrieved by the High Court’s decision, the appellants moved the Supreme Court.

Supreme Court’s Key Observations

1. The Need for Caution in Criminalizing Family Relationships

• The Supreme Court stated:
  • “Domestic relationships, such as those between family members, are guided by deeply ingrained social values and cultural expectations. These relationships are often viewed as sacred, demanding a higher level of respect, commitment, and emotional investment compared to other social or professional associations.”
  • “Thus, when family relationships are sought to be brought within the ambit of criminal proceedings rupturing the family bond, courts should be circumspect and judicious.”

2. Lack of Direct Witness Testimonies

• The Court perused the charge sheet and complaint and found:
  • The allegations of harassment were only communicated by the complainant to her parents, who did not witness the alleged acts.
  • The complainant herself did not mention any physical assault in her complaint.
  • The parents' statements, which claimed the complainant was beaten, were additional allegations not present in the original complaint.
  • The statements of two Panchayat elders were hearsay evidence, and their presence in the Panchayat meeting was unexplained.

3. General Allegations Against Appellants

• The Court found that while specific allegations were present against the husband and mother-in-law, the accusations against the other relatives (i.e., the present appellants) were general and vague.
• The Court ruled:
  • “There may be situations where some of the family members or relatives may turn a blind eye to the violence or harassment perpetrated on the victim, and may not extend any helping hand to the victim, which does not necessarily mean that they are also perpetrators of domestic violence.”
  • “Implicating all such relatives without making specific allegations and attributing offending acts to them, and proceeding against them without prima facie evidence that they were complicit, would amount to abuse of the process of law.”

Balancing the Rights of Victims and Accused

• The Supreme Court recognized the importance of protecting victims of domestic violence but warned against the misuse of criminal law.
• It stated:
  • “The purpose and mandate of the law to protect the victims of domestic violence is of paramount importance, and as such, a balance has to be struck by ensuring that while perpetrators are brought to book, all the family members or relatives are not indiscriminately brought within the criminal net in a sweeping manner.”
• The Court further clarified that its observations will not apply in cases where relatives have actively participated in the cruelty.

Final Judgment

• Based on the absence of specific allegations and lack of direct evidence, the Supreme Court ruled that no prima facie case was made out against the appellants.
• Consequently, the criminal proceedings against them were quashed.
• However, the Court explicitly stated that its findings will not affect the criminal proceedings against the husband and mother-in-law.

Legal Implications & Precedents

• The judgment reinforces the principle that criminal law should not be misused to settle personal vendettas in domestic disputes.
• It aligns with the Supreme Court’s previous rulings, cautioning against the over-implication of distant relativesin dowry and domestic violence cases.
• The Court emphasized the importance of specific allegations and credible evidence, warning against filing sweeping complaints against extended family members.

Case Title: Geddam Jhansi & Anr. v. The State of Telangana & Ors.