Generalized matrimonial allegations lacking medical or independent corroboration cannot sustain a criminal conviction.

The complainant (Savita Jaiswal) married accused No. 3 (Rajnish Jaiswal) on April 26, 2016.

She alleged that after one month of marriage, her husband and in-laws (accused Nos. 1 and 2) began harassing her for dowry, specifically demanding a vehicle and money.

She further alleged that the accused forcibly caused a miscarriage in June 2016 and that her husband assaulted her on March 13, 2017, by kicking her abdomen, leading to a second miscarriage.

A written complaint was lodged on May 26, 2017, leading to an FIR under Sections 498A, 313, 323, 506, and 34 of the IPC.

The Trial Court acquitted the respondents of all charges on March 9, 2020, concluding the prosecution failed to prove the allegations beyond reasonable doubt.

Both the complainant and the State appealed against the acquittal.

1. Whether the respondents subjected the complainant to cruelty and harassment in connection with dowry demands under Section 498A of the IPC.

2. Whether accused No. 3 caused a miscarriage without the complainant's consent, punishable under Section 313 of the IPC, and committed acts of assault and criminal intimidation under Sections 323 and 506 of the IPC.

The Court applied the definition of 'cruelty' under Section 498A of the IPC, relying on Manju Ram Kalita v. State of Assam, which established that cruelty must be continuous, persistent, or in close proximity to the complaint, distinguishing it from petty marital quarrels.

Regarding the implication of family members, the Court cited Dara Lakshmi Narayana v. State of Telangana, which cautions against sweeping accusations against in-laws without specific evidence of active involvement.

It further relied on Achin Gupta v. State of Haryana, emphasizing that courts must distinguish between the "normal wear and tear" of a marriage and criminal cruelty to prevent the misuse of legal provisions.

The Court found material contradictions in the complainant's testimony; while her initial written complaint (Ex. P/1) mentioned a demand for a vehicle, her court statement introduced a new demand for Rs. 10,00,000 for her brother-in-law’s employment.

Regarding the charge under Section 313 IPC, medical evidence from PW-8 and PW-9 characterized the pregnancy loss as a "missed abortion" and confirmed there were no external injury marks on the complainant’s body.

The doctors testified that 70-80% of such cases occur naturally, failing to link the miscarriage to physical trauma.

Furthermore, independent neighbors (PW-5 and PW-6) did not support the allegations of abuse, stating the couple lived harmoniously.

The Court also noted the Protection Officer’s testimony (PW-7) that the complainant refused to participate in reconciliation or inquiry unless the in-laws complied with her specific wishes.

Consequently, the Court inferred that the complainant likely used dowry allegations to address a lack of personal compatibility, especially since the marriage had already been dissolved by divorce.

It found no illegality or infirmity in the Trial Court’s judgment. The Court affirmed the acquittal of all respondents, dismissing both the complainant’s and the State’s appeals.

The appeals failed as the evidence suggested the allegations were an attempt to criminalize domestic discord following the breakdown of the marriage.