RAJESH CHADDHA versus STATE OF UTTAR PRADESH

Citation: [2025] 6 S.C.R. 382 · Decided: 12-05-2025 · Supreme Court of India · Bench: B.V. NAGARATHNA · Disposal: Appeal(s) allowed

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Judgment (excerpt)

[2025] 6 S.C.R. 382 : 2025 INSC 671
Rajesh Chaddha 
v. 
State of Uttar Pradesh
(Criminal Appeal No(s). 2635-2636 of 2025)
13 May 2025
[B.V. Nagarathna and Satish Chandra Sharma,* JJ.]
Issue for Consideration
Whether the High Court while exercising its revisionary jurisdiction 
erred in upholding the conviction of the appellant under Section 
498A, Penal Code, 1860 and Section 4, Dowry Prohibition Act, 1961.
Headnotes†
Penal Code, 1860 – s.498A – Dowry Prohibition Act, 1961 – 
s.4 – Conviction under – When not sustainable:
Held: The term “cruelty” is being misused and cannot be 
established simpliciter without specific instances – The tendency 
of roping sections 498A, IPC and 3 & 4, DP Act, 1961 without 
mentioning any specific dates, time or incident, weakens the case 
of the prosecution casting serious suspicion on the viability of the 
version of a complainant – In the present case, the allegations 
made by the complainant-wife were vague, omnibus and bereft of 
any material particulars to substantiate the threshold of offences 
u/s.498A, IPC and s.4, DP Act, 1961 – A cursory or plausible view 
cannot be conclusive proof to determine the guilt of an individual 
under the aforesaid Sections, especially to obviate malicious 
criminal prosecution of family members in matrimonial disputes – 
FIR registered by the complainant was not genuine – Nothing 
incriminatory against the appellant to sustain conviction u/s.498A, 
IPC or s.4, DP Act, 1961 – Impugned order set aside – Appellant 
acquitted. [Paras 9, 11, 12, 14, 15]
Penal Code, 1860 – s.498A – Dowry Prohibition Act, 1961 – 
ss.3, 4 – Threshold of offences under:
Held: An act of ‘cruelty’ for the purpose of s.498A, corresponds 
to a willful conduct of such nature, that may cause danger to the 
life, limb and health of the woman, which is inclusive of the mental 
and physical health and the harassment caused to her, by coercing 
* Author
[2025] 6 S.C.R. 
383
Rajesh Chaddha v. State of Uttar Pradesh
her to meet unlawful demands or impossible standards – Further, 
the demand for dowry in terms of ss.3 and 4 of the DP Act, 1961 
refers to both a direct or indirect manner of demand for dowry made 
by the husband or his family members – To meet the threshold 
of the offences u/s.498A, IPC and ss.3 and 4, DP Act, 1961, the 
allegations cannot be ambiguous or made in thin air. [Para 8]
Judicial Deprecation – Penal Code, 1860 – s.498A – Dowry 
Prohibition Act, 1961 – ss.3, 4 – Practice of maliciously 
roping in of every relative of husband, deprecated – Misuse 
of s.498A – Discussed. [Paras 13, 14]
Case Law Cited
Dara Lakshmi Narayana & Ors. v. State of Telangana & Anr. [2024] 
12 SCR 559 : (2025) 3 SCC 735 – relied on.
Bhagwan Jagannath Markad v. State of Maharashtra [2016] 5 SCR 
452 : (2016) 10 SCC 537; Arun Vyas & Anr. v. Anita Vyas [1999] 3 
SCR 719 : (1999) 4 SCC 690; Surendran v. State of Kerala [2022] 
4 SCR 675 : (2022) 15 SCC 273 – referred to.
List of Acts
Penal Code, 1860; Dowry Prohibition Act, 1961.
List of Keywords
Section 498A, Penal Code, 1860; Sections 3, 4, Dowry Prohibition 
Act, 1961; Cruelty; Misuse of Section 498A, Penal Code, 1860; 
Allegations vague; Omnibus; Bereft of any material particulars; 
Malicious criminal prosecution of family members; Matrimonial 
disputes; Dowry; No particular instance of harassment; FIR not 
genuine; Revisionary jurisdiction; Missing specifics in a criminal 
complaint; Malicious roping in of every relative of husband;  
Co-accused parents-in-law; Section 323, Penal Code, 1860 read with 
Section 34 & Section 506; Hurt; Miscarriage; Criminal intimidation.
Case Arising From
CRIMINAL APPELLATE JURISDICTION: Criminal Appeal  
No(s). 2635-2636 of 2025
From the Judgment and Order dated 14.11.2018 and 28.11.2018 
of the High Court of Judicature at Allahabad, Lucknow Bench in 
CRR No. 612 of 2004 and CRMA No. 131658 of 2018, respectively
384
[2025] 6 S.C.R.
Supreme Court Reports
Appearances for Parties
Adv. for the Petitioner:
Ms. Preetika Dwivedi.
Advs. for the Respondent:
Shaurya Sahay, Aditya Kumar, Ms. Ruchil Raj.
Judgment / Order of the Supreme Court
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 f

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