Article 227 does not warrant interference with a reasonably supportable discharge order.

The petitioner alleged dowry demands, cruelty and retention of her istridhan by her husband and his family.

The Magistrate directed charges against all accused under Sections 498-A and 406 IPC.

In revision, the Sessions Court discharged the husband under Section 406 IPC and discharged his relatives under both provisions, while retaining the Section 498-A charge against the husband.

During the petition, the husband was acquitted under Section 498-A after the petitioner and her mother could not be served and her father had died; the petitioner withdrew her application to set aside that acquittal, with liberty to pursue appropriate proceedings.

The petitioner challenged the revisional order under Article 227 of the Constitution.

Whether the revisional court’s discharge of the husband’s relatives under Section 498-A IPC was so legally flawed or unsupported as to warrant interference under Article 227

Whether the discharge of all accused under Section 406 IPC disclosed patent illegality or perversity warranting supervisory interference

Article 227 confers supervisory, not appellate, jurisdiction; interference is warranted for grave dereliction, patent illegality, perversity or a finding unsupported by evidence, not merely because another view is possible (*Garment Craft v. Prakash Chand Goel*, (2022) 4 SCC 181).

At the charge stage, the court considers whether the material, taken at face value, discloses the ingredients of an offence or gives rise to a presumption or strong suspicion; it must not conduct a meticulous assessment of evidentiary worth (*Amit Kapoor v. Ramesh Chander*, (2012) 9 SCC 460; *Union of India v. Prafulla Kumar Samal*, (1979) 3 SCC 4; *Onkar Nath Mishra v. State (NCT of Delhi)*, (2008) 2 SCC 561).

Section 498-A IPC covers qualifying wilful conduct likely to drive a woman to suicide or cause grave injury or danger to her health, and harassment to coerce fulfilment of an unlawful property demand; allegations against relatives must disclose their participation, while avoiding both indiscriminate implication and premature disbelief (*Neelu Chopra v. Bharti*, (2009) 10 SCC 184; *Kahkashan Kausar v. State of Bihar*, (2022) 6 SCC 599).

Section 406 IPC requires both entrustment or dominion over property and subsequent dishonest misappropriation, conversion, use, disposal or retention in breach of the relevant obligation.

The court found that the allegations against the husband included specific acts of assault and receipt or withdrawal of money, whereas the allegations against his relatives were largely collective and did not sufficiently identify their individual participation in statutory cruelty.

The allegation that the mother-in-law required the petitioner to perform household work did not, without more, meet Section 498-A’s threshold; the allegation that a sister-in-law administered medicines was considered alongside medical records describing the miscarriage as spontaneous and lacking a contemporaneous history of forced medication.

The court disapproved the revisional court’s conjecture about the car model and its reliance on the petitioner’s attempt to return to the matrimonial home, but held that the discharge of the relatives remained independently supportable.

On Section 406, the complaint identified categories of articles and where they were allegedly held, but did not adequately show how particular property was entrusted to each accused or how each dishonestly dealt with it; collective allegations of demands and refusal did not cure those deficiencies.

In light of Article 227’s limited scope, the court declined to substitute its view for a reasonably open conclusion.

The discharge of the respondents under Section 406 IPC and of respondents 4–6 under Section 498-A IPC therefore remained undisturbed; proceedings against respondent 3 had abated on his death.

The pending application was disposed of and any interim orders were vacated.