Supreme Court Quashes Conviction under Section 498A IPC in Matrimonial Dispute After Settlement: Rajendra Bhagat vs. State of Jharkhand (2022) INSC 1

Date of the Judgment: 3 January 2022
Citation: (2022) INSC 1
Judges: Hon’ble Mr. Justice Dinesh Maheshwari and Hon’ble Mr. Justice Vikram Nath
Can a conviction under Section 498A of the Indian Penal Code, 1860 be quashed after a couple resolves their marital disputes and decides to live together? The Supreme Court of India addressed this question in a recent case, emphasizing the importance of encouraging genuine settlements in matrimonial matters. The court ultimately quashed the conviction, recognizing that maintaining it would be counterproductive to the couple’s reconciliation. This judgment highlights the court’s view on the need to prioritize the well-being of families and encourage amicable resolutions in matrimonial disputes. The bench consisted of Hon’ble Mr. Justice Dinesh Maheshwari and Hon’ble Mr. Justice Vikram Nath.

Case Background

Rajendra Bhagat, the appellant, was serving in the Indian Army as Naik. He married Respondent No. 2 on 25 May 2013. Due to marital disputes, Respondent No. 2 filed a First Information Report (FIR) on 2014 at Police Station, Sisai, alleging dowry demands, mental and physical torture against the appellant and his family. A chargesheet was filed on 26 November 2014 under Sections 498-A, 323, 417, and 34 of the Indian Penal Code, 1860 (IPC).

The Judicial Magistrate, First Class, Gumla, convicted the appellant under Section 498-A of the IPC and other accused persons under Section 323 of the IPC, while acquitting them of the charges under Sections 417 and 34 of the IPC. Except for the appellant, all other accused persons were given the benefit of the Probation of Offenders Act, 1958. The appellant was sentenced to three years of simple imprisonment. The Sessions Judge, Gumla, dismissed the appellant’s appeal on 30 May 2019.

The appellant then filed a revision petition before the High Court of Jharkhand at Ranchi. While the revision petition was pending, the appellant was dismissed from his military service on 14 July 2020, due to his conviction under Section 498-A of the IPC. On 24 November 2020, the appellant and Respondent No. 2 submitted a joint application to the High Court, stating that they had settled their disputes and were living together harmoniously.

Timeline

Course of Proceedings

The High Court of Jharkhand, while acknowledging the settlement between the parties, modified the sentence of the appellant to the period of imprisonment already undergone. However, it upheld the conviction under Section 498-A of the IPC. The High Court noted that continuing the proceedings might lead to disharmony but did not quash the conviction.

Legal Framework

The case primarily revolves around Section 498-A of the Indian Penal Code, 1860, which deals with cruelty by a husband or his relatives towards a woman.

Section 498-A of the Indian Penal Code, 1860 states:
“Whoever, being the husband or the relative of the husband of a woman, subjects such woman to cruelty shall be punished with imprisonment for a term which may extend to three years and shall also be liable to fine.”

Arguments

The appellant and Respondent No. 2 jointly submitted that they had resolved their marital disputes and were living together harmoniously. They argued that the dispute was a result of miscommunication and misunderstanding. They requested the High Court to dispose of the revision petition in light of the changed circumstances.

The appellant contended that the High Court erred in not setting aside the conviction despite taking note of the settlement between the parties. The appellant argued that maintaining the conviction would not serve the ends of justice, especially since it led to his dismissal from service, which would cause financial distress to the family.

The State did not oppose the settlement but did not make any specific submissions.

Issues Framed by the Supreme Court

The Supreme Court framed the following issue for consideration:

1. Whether the High Court, even after taking note of the settlement of the parties resolving their marital disputes, erred in not setting aside the order of conviction altogether?

Treatment of the Issue by the Court

Authorities

The Supreme Court relied on the following authorities:

Judgment

The Supreme Court allowed the appeal and quashed all proceedings arising out of FIR No. 204 of 2014 against the appellant. The Court set aside the order of conviction, emphasizing that maintaining the conviction would be counterproductive to the couple’s reconciliation and would lead to further financial distress for the family.

What weighed in the mind of the Court?

The Supreme Court was primarily influenced by the fact that the parties had genuinely settled their disputes and were living together harmoniously. The Court recognized that maintaining the conviction would not serve the ends of justice and would adversely affect the family’s well-being. The Court’s decision was also guided by the need to encourage genuine settlements in matrimonial disputes, as highlighted in previous judgments.

The Court observed that “maintaining of conviction of the appellant of the offence under Section 498-A IPC would not be securing the ends of justice and with such conviction being maintained and the appellant losing his job, the family would again land itself in financial distress which may ultimately operate adverse to the harmony and happy conjugal life of the parties.”

The Court further stated, “The special features in such matrimonial matters are evident. It becomes the duty of the court to encourage genuine settlements of matrimonial disputes.”

The Court also noted, “There is every likelihood that non-exercise of inherent power to quash the proceedings to meet the ends of justice would prevent women from settling earlier. That is not the object of Chapter XX-A of the Penal Code, 1860.”

Key Takeaways

• ✓ Courts should encourage genuine settlements in matrimonial disputes.
• ✓ Maintaining a conviction under Section 498-A of the IPC after a settlement can be counterproductive.
• ✓ The well-being of the family should be a primary consideration in such cases.
• ✓ The Supreme Court can exercise its inherent powers to quash criminal proceedings to secure the ends of justice.

Directions

The Supreme Court quashed all proceedings arising out of FIR No. 204 of 2014 against the appellant and set aside the order of conviction.

Development of Law

The ratio decidendi of this case is that in matrimonial disputes, if the parties have genuinely settled their differences and are living together harmoniously, the courts should not hesitate to quash criminal proceedings under Section 498A of the IPC, even if a conviction has been recorded. This decision reinforces the principle that the primary objective of the legal system in matrimonial disputes should be to encourage reconciliation and protect the well-being of the family. This case reaffirms the position of law laid down in B.S. Joshi and Bitan Sengupta.

Conclusion

The Supreme Court’s decision in Rajendra Bhagat vs. State of Jharkhand emphasizes the importance of encouraging genuine settlements in matrimonial disputes. By quashing the conviction under Section 498-A of the IPC, the Court prioritized the well-being of the family and reinforced the principle that the legal system should promote reconciliation and harmony in such cases.