The Supreme Court has emphasized the need for a careful and cautious approach in cases of dowry harassment allegations to prevent misuse of the law. While these provisions are intended to protect women from cruelty and dowry-related abuse, the court warned that they should not be exploited to settle personal scores or pursue ulterior motives.

A bench of Justices Vikram Nath and Sandeep Mehta allowed a criminal appeal by a man and his parents to quash a criminal case initially lodged under Section 498-A, 504, 506 of IPC, Sections 3(1)(r), 3(1)(s) and 3(1)(w) of the Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act, 1989,2 and Sections 3 and 4 of the Dowry Prohibition Act, 1961 on a complaint filed by his wife.

The high court had only partly allowed their plea to quash the case against them, refusing to quash the proceedings under Section 498A and Sections 3 and 4 of the DP Act.

Having examined their appeal against the high court's decision, the apex court noted that the allegations against the appellants were devoid of merit, manifestly frivolous, and failed to disclose a prima facie case. "The continuation of criminal proceedings in such circumstances would amount to an abuse of the process of law and result in a miscarriage of justice", it held.

"Criminal law should not be used as a tool for harassment or vendetta. The allegations in a criminal complaint must be scrutinised with care to ensure that they disclose a prima facie case before subjecting individuals to the rigors of a criminal trial," the bench said.

In the complaint lodged on February 10, 2019, the woman had alleged cruelty and harassment at the hands of the appellants. The complainant alleged that that at the time of marriage, a swift car, a gold chain of 80 grams, a ring, and a bracelet weighing about 50 grams, among other gifts were given and the marriage was performed at an expense of Rs 45,00,000.

She claimed that she belonged to a scheduled caste, while the husband belonged to the Brahmin caste, and that they fell in love with each other and thereafter got married. She further claimed that her father had paid several amounts to the husband for rent, his foreign travels, etc upon demands made by him. She also alleged that he was addicted to alcohol and drugs, and used to mentally harass her. Further, she claimed that her in-laws would also harass her and make caste-based remarks whenever they used to visit them in Bangalore, where the couple was residing.

As the police filed the charge sheet and the trial court took cognizance of the offences alleged, the appellants approached the Karnataka High Court which said the allegations contained charges of cruelty and dowry demands, and it required examination by the trial court.