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Family LawSupreme Court of India

Rajesh Chaddha v. The State of Uttar Pradesh

Criminal Appeal · 2025 INSC 671Decided 13 May 2025
Crl.A. No.-002635-002636 - 2025 (arising out of SLP (Crl.) Nos. 2353-2354 of 2019)
Mrs. Justice B.V. Nagarathna · Justice Satish Chandra Sharma

Background

The appellant husband was convicted by a Magistrate in 2004 for subjecting his wife to cruelty and demanding dowry, a conviction upheld on appeal by the Sessions Court and later in revision by the Allahabad High Court. The wife had lived with him for only about a year before separating, and alleged she was harassed, beaten, and suffered a miscarriage due to physical assault, though no medical evidence was ever produced to support the miscarriage or injury claims. The FIR was lodged after the husband had already filed for divorce, and the couple's divorce had since become final.

Decision Breakdown

The Supreme Court found the wife's allegations to be vague and generalised, lacking specific dates, times, or details of the alleged harassment, and noted the complete absence of any medical evidence for the claimed physical assault or miscarriage. The trial court itself had already acquitted the husband and his family of assault and criminal intimidation charges for lack of evidence, yet convicted him on the dowry-related charges based on the same unsubstantiated testimony. The Court also flagged the pattern of matrimonial cases being used to rope in family members without specific allegations, and set aside the conviction, acquitting the appellant of all charges.

Lesson Learnt

A criminal conviction for cruelty or dowry demand cannot rest on vague, unparticularised allegations unsupported by evidence such as medical records. Courts must guard against Section 498A being used as a tool of harassment in matrimonial disputes rather than genuine protection.

Rajesh Chaddha v. The State of Uttar Pradesh – Legal Case Shots | LegalAware