Concurrent findings of acquittal under Section 498-A IPC cannot be disturbed absent jurisdictional error or patent illegality.

The petitioner (complainant) married opposite party No. 2 in June 2000.

She alleged that after the birth of two daughters in 2003 and 2006, her husband and in-laws subjected her to physical and mental torture, demanding ₹50,000 and a color TV as additional dowry.

She further alleged that in 2008, her in-laws assaulted her and drove her out of the matrimonial home.

A complaint case (No. 1342 of 2008) was filed under Section 498-A of the IPC.

The Trial Court (J.M. 1st Class, Hazaribagh) acquitted the accused, a decision subsequently upheld by the Sessions Judge, Hazaribagh, in Cr. Appeal No. 72 of 2018.

The petitioner approached the High Court in revision challenging these concurrent findings of acquittal.

1. Whether the findings of the lower courts in acquitting the accused were perverse or suffered from legal infirmity warranting interference in revisional jurisdiction.

2. Whether the allegations of cruelty and dowry demand under Section 498-A IPC were proved beyond reasonable doubt.

Section 498-A of the Indian Penal Code (IPC), which defines and punishes matrimonial cruelty.

Procedural principles governing Section 397 and 401 of the Cr.P.C. regarding revisional jurisdiction, specifically the doctrine that a revisional court cannot re-appreciate evidence as an appellate court but must confine itself to the legality, propriety, and correctness of the order.

The High Court observed that both the trial and appellate courts concurrently found that from the date of marriage in 2000 until 2008, the complainant had made no formal complaints against her in-laws.

The court noted that the husband had left for Nagpur for work in 2007, and the complainant remained at the matrimonial home for 1.5 years thereafter before returning to her parents.

The court reasoned that the alleged "wear and tear of life" experienced during her stay did not meet the legal threshold of "cruelty" as defined under Section 498-A IPC.

Furthermore, the court held that the petitioner failed to point out any serious error of law or perversity, instead merely requesting a re-evaluation of evidence, which is outside the scope of revisional jurisdiction.

The court dismissed the criminal revision, finding no merit in the petitioner's contentions and vacated all interim orders.