The Supreme Court of India in a significant judgment (2025 INSC 1051) has acquitted a mother-in-law who was earlier convicted under Section 498-A of the Indian Penal Code (IPC) for alleged dowry harassment. This ruling reaffirms the principle that mere allegations without reliable evidence cannot sustain a conviction under Section 498-A IPC.

This judgment will have a wide impact on dowry harassment cases, matrimonial disputes, and criminal trials under Section 498-A IPC, where courts must carefully evaluate the credibility of evidence before conviction.

The appellant, Smt. Bhagwati Devi (mother-in-law), was convicted by the Sessions Court and her conviction was upheld by the Uttarakhand High Court.

Allegations:

The deceased (Chandra Devi) was married to the appellant’s son in 2000–2001.

She was found dead in her matrimonial home in June 2001.

The complainant (father of deceased) alleged sarcastic remarks and harassment for dowry by the mother-in-law.

 Husband was away in Mumbai on work at the time of the incident.

Charges framed: Section 304-B IPC, Section 498-A IPC, and alternate charge under Section 302/34 IPC.

1. Definition of Cruelty under Section 498-A IPC

 Cruelty includes harassment for dowry or conduct likely to drive a woman to commit suicide.

 Demand for dowry in any form is punishable under Section 498-A IPC.

 2. Evidence of the Complainant (PW-1)

 The father’s complaint did not mention any specific demand of dowry by the mother-in-law.

His deposition failed to establish harassment that could amount to cruelty under Section 498-A IPC.

 3. Testimony of Deceased’s Mother (PW-3)

 Made allegations in court for the first time.

 Admitted that at marriage there was no dowry demand.

 Admitted that her daughter had cordial married life initially.

 Court held her testimony unreliable.

 4. Testimony of Deceased’s Brother (PW-2)

 Confirmed there was no demand for dowry at the time of marriage.

 Stated that his belief of “murder” was only a doubt, not based on facts.

 5. Medical Evidence (PW-4)

 Cause of death: Asphyxia due to strangulation.

 Doctor admitted absence of other expected injuries in strangulation cases, raising doubt.

 6. Independent Neighbour Witness (DW-1 – Janki Devi)

 Categorically stated that no demand for dowry was made by the appellant.

 Also said that deceased only mentioned “not keeping well.”

 The Court emphasized that:

“Word spreads faster than the wind about a daughter-in-law being harassed for dowry.”

 Her testimony was wrongly discarded by trial & high courts.

The conviction of the appellant under Section 498-A IPC was not sustainable.

 Supreme Court set aside the High Court judgment and acquitted the mother-in-law.

 Bail bonds discharged.

Independent witnesses play a crucial role.

Conviction cannot rest solely on uncorroborated statements of interested witnesses.

Courts must ensure specific evidence of cruelty/demand for dowry before convicting.

Medical evidence must support prosecution’s case; otherwise, benefit of doubt goes to accused.

This ruling strengthens the principle that Section 498-A IPC cannot be misused based on vague allegations. It provides relief to innocent relatives of the husband, especially mothers-in-law, who are often falsely implicated in dowry harassment cases.

For individuals facing false dowry harassment cases under Section 498-A IPC, this judgment is a guiding precedent to ensure justice.