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Supreme Court of India · 12/05/2025

RAJESH CHADDHA versus STATE OF UTTAR PRADESH

[2025] 6 S.C.R. 382 · 2025 INSC 671

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Summary

The appellant husband's conviction under Section 498A IPC and Section 4 of the Dowry Prohibition Act, 1961, affirmed in appeal and in revision by the High Court, was set aside. The complainant's allegations of dowry harassment were vague and omnibus, without date, time, place or any specific instance, the alleged assault and miscarriage were unsupported by any medical evidence, the only evidence was the testimony of the complainant and her father, and the FIR was lodged after the husband had filed for divorce. A cursory or plausible view cannot be conclusive proof of guilt, and the High Court in revision ought to have examined whether the conviction was sustainable on the record.

Issues

  1. Whether the High Court, exercising revisional jurisdiction, was correct in upholding the appellant's conviction under Section 498A IPC and Section 4 of the Dowry Prohibition Act, 1961.
  2. Whether vague and omnibus allegations of cruelty and dowry demand, lacking particulars of date, time, place or incident and resting only on the testimony of the complainant and her father, can sustain such a conviction.
  3. Whether the High Court's order was vitiated because it was passed when no counsel appeared for the appellant.

Provisions considered

Held

Result

Appeals allowed. The High Court's order dated 14.11.2018 in Criminal Revision No. 612/2004 upholding the conviction under Section 498A IPC and Section 4 of the Dowry Prohibition Act, 1961 set aside; appellant acquitted of all charges. Pending applications disposed of.

Judgment PDF: Supreme Court of India, [2025] 6 S.C.R. 382.