In a significant ruling, the Karnataka High Court has made it clear that neighbours or strangers cannot be casually implicated in dowry harassment cases arising from matrimonial disputes. The court recently quashed criminal proceedings against a Bengaluru woman who was named as an accused by her neighbour in a domestic conflict.
Court Grants Relief to Bengaluru Resident
The High Court granted relief to Bengaluru resident Asha G, setting aside the proceedings initiated against her based on a complaint filed by her neighbour, Munirathnamma. Justice M Nagaprasanna, while delivering the judgment, observed that a stranger cannot be drawn into proceedings for offences under Section 498A of the Indian Penal Code (IPC), which is meant for disputes between husband, wife, or immediate family members.
Background of the Matrimonial Dispute Case
The case originated from a complaint lodged at the Mahalakshmi Layout police station on February 13, 2021. In her complaint, Munirathnamma accused her husband Muthuram, his family members, and their next-door neighbour Asha of subjecting her to cruelty and harassment. The police registered a case under Sections 498A, 504, 506, and 323 of the IPC.
Later, a chargesheet was filed naming Asha as accused number 5. The allegation against her was singular: that she had instigated the husband against his wife.
High Court's Scrutiny and Rationale
Challenging the proceedings, Asha contended she had no role in the complainant's matrimonial life and was "only a neighbour". She argued the lone allegation of instigation was insufficient to rope her into a dowry case and that she was targeted due to a personal vendetta ("an axe to grind"). The complainant, however, maintained that Asha was the "reason for all the behaviour" of her husband and should face trial.
After examining the chargesheet, Justice Nagaprasanna noted a critical flaw. The judge found that the petitioner's name surfaced "nowhere except for the contention that she instigated the husband to torture the wife". The court held that Asha did not fall within the definition of "family" as contemplated under Section 498A.
Relying on a previous Supreme Court ruling, the judge reiterated the apex court's position that a stranger cannot be drawn into Section 498A proceedings. The court concluded that allowing the case to continue against Asha would become an abuse of the process of law and result in a miscarriage of justice.
Proceedings Quashed, But With a Caveat
Accordingly, the High Court quashed the proceedings pending before the Chief Metropolitan Magistrate in Bengaluru, but only insofar as they concerned Asha. Justice Nagaprasanna clarified that the court's observations were made solely for the purpose of considering this petitioner's plea and would not apply to any other accused or influence the further proceedings against the remaining individuals in the case.
This judgment underscores the judiciary's intent to prevent the misuse of stringent anti-dowry laws and protects individuals outside the immediate familial sphere from being entangled in personal marital discord without substantial and specific evidence.
