Taunting and Assigning Household Chores Without Willful Cruelty or Unlawful Demands Does Not Constitute Section 498A IPC Offences

The petitioners filed this petition under Section 482 of the Cr.P.C. seeking to quash a criminal proceeding (Complaint Case No. 1397 of 2021) and the summoning order dated 11.11.2022.

The complainant (Opposite Party No. 2) alleged that following her husband's death, her in-laws (Petitioners 1 and 2, the father-in-law and mother-in-law) taunted her by saying she "had eaten up her husband" and forced her to perform all household chores.

Petitioner No. 3 (the brother-in-law) faced allegations under Sections 498A, 354, and 506 IPC, but withdrew his prayer during the proceedings with liberty to raise grounds at a later stage.

The trial court had found a prima facie case against Petitioners 1 and 2 specifically under Section 498A IPC.

1. Whether the allegations of taunting and being made to do household chores, as alleged against Petitioners 1 and 2, satisfy the ingredients of "cruelty" required to constitute an offence under Section 498A of the IPC.

The Court applied Section 498A of the Indian Penal Code, which defines "cruelty" as any willful conduct likely to drive a woman to suicide or cause grave injury/danger to life, limb, or health, or harassment to coerce her or her relatives to meet unlawful demands for property or valuable security.

The Court also relied on its previous judgment in Pushpendra Kumar Singh vs. The State of Jharkhand & Another (Cr.M.P. No. 241 of 2024), which outlines the essential ingredients necessary to sustain a charge under Section 498A IPC.

The Court evaluated the allegations against Petitioners 1 and 2—specifically the taunts regarding the death of the complainant's husband and the requirement to perform household chores—against the statutory definition of "cruelty".

The Court observed that there were no allegations of "willful conduct" of such a nature that would likely drive the complainant to suicide or cause danger to her life, limb, or mental/physical health.

The record lacked any evidence suggesting the petitioners caused harm to coerce her into meeting unlawful demands.

Even if the allegations were accepted as true in their entirety, they failed to meet the legal threshold for an offence under Section 498A IPC.

Ordered the quashing of the entire criminal proceeding in Complaint Case No. 1397 of 2021, including the summoning order dated 11.11.2022, insofar as they related to Petitioners 1 and 2.

The petition was dismissed as withdrawn regarding Petitioner 3.