Supreme Court Reduces Sentence in Dowry Harassment Case: M. Venkateswaran vs. State (2025)

Introduction

Date of the Judgment: 24 January 2025

Citation: 2025 INSC 106

Judges: K.V. Viswanathan, J., S.V.N. Bhatti, J.

Can a conviction for dowry harassment be upheld even when the marriage lasted only three days? The Supreme Court of India recently addressed this question, examining the evidence and modifying the sentence in a case involving allegations of dowry demands and harassment shortly after a marriage. The court considered the facts, the evidence presented, and the prolonged nature of the legal proceedings to arrive at a decision.

This judgment was delivered by a bench comprising Justices K.V. Viswanathan and S.V.N. Bhatti, with the majority opinion authored by Justice K.V. Viswanathan.

Case Background

The marriage between the complainant (PW-4) and the appellant took place on March 31, 2006, but lasted only three days. Following the marriage, the complainant filed a police report on August 23, 2007, alleging that the appellant, his father (A-2), and brother (A-3) had committed offenses under Section 498A, 406, 420, and 506(2) of the Indian Penal Code, 1860 (IPC), and Section 4 of the Dowry Prohibition Act, 1961 (DP Act).

The prosecution examined 15 witnesses and presented 46 documents, while the appellant examined himself and marked 10 exhibits. The case against the appellant’s father (A-2) abated due to his death during the trial.

The 4th Metropolitan Magistrate Court, Saidapet, acquitted A-3 of all charges but convicted the appellant under Sections 406, 498A of the IPC and Section 4 of the DP Act. The appellant was sentenced to three years imprisonment and a fine of Rs. 3,000 for the offense under Section 498A of the IPC, and one year of simple imprisonment for the offense under Section 4 of the DP Act. The XVth Additional Sessions Judge set aside the conviction under Section 406 of the IPC but upheld the other convictions and sentences. The High Court of Judicature at Madras, in revision, confirmed the conviction but modified the sentence to two years imprisonment under Section 498A of the IPC.

Timeline:

Course of Proceedings

The 4th Metropolitan Magistrate Court, Saidapet, acquitted A-3, the appellant’s brother, from all charges. However, the appellant was convicted under Section 406, 498A of the IPC and Section 4 of the DP Act. The trial court sentenced him to three years imprisonment and a fine of Rs. 3,000 for the offense under Section 498A of the IPC, and one year of simple imprisonment for the offense under Section 4 of the DP Act.

On appeal, the XVth Additional Sessions Judge set aside the conviction under Section 406 of the IPC but confirmed the conviction under Section 498A of the IPC and Section 4 of the DP Act, also confirming the sentence. On further challenge in revision, the High Court, while confirming the conviction, modified the sentence to two years imprisonment under Section 498A of the IPC.

Legal Framework

The case primarily involves the following legal provisions:

• Section 498A of the Indian Penal Code, 1860 (IPC): This section deals with cruelty by a husband or his relatives towards a woman. It 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.”
• Section 4 of the Dowry Prohibition Act, 1961 (DP Act): This section penalizes demanding dowry. It states, “If any person demands, directly or indirectly, from the parents or other relatives or guardian of a bride or bridegroom, as the case may be, any dowry, he shall be punishable with imprisonment for a term which shall not be less than six months, but which may extend to two years and with fine which may extend to ten thousand rupees.”

These provisions are designed to protect women from harassment and violence related to dowry demands and to ensure a safe and dignified life for them within their marital homes.

Arguments

Appellant’s Arguments:

• The appellant argued that the High Court should not have upheld the conviction under Section 498A of the IPC and Section 4 of the DP Act.
• The appellant contended that the evidence presented did not sufficiently prove the charges against him.

Respondent’s Arguments:

• The State argued that the evidence clearly demonstrated the appellant’s guilt under Section 498A of the IPC and Section 4 of the DP Act.
• The State emphasized the consistent testimony of the witnesses, particularly the complainant (PW-4), and her family members, who spoke about the dowry demands and the harassment faced by the complainant.

Sub-Submissions:

Issues Framed by the Supreme Court

The Supreme Court considered the following issues:

1. Whether the conviction of the appellant under Section 498A of the IPC and Section 4 of the DP Act was justified based on the evidence on record.
2. If the conviction was justified, what would be the appropriate sentence, considering the facts and circumstances of the case.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The Court considered the following authorities:

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

• Sama ul Sk. vs. The State of Jharkhand & Anr. (2021 INSC 429)*: The Supreme Court followed the approach of reducing the sentence to the period already undergone and directing payment of compensation.

What weighed in the mind of the Court?

The Supreme Court’s decision was influenced by a combination of factors, including the overwhelming evidence of harassment and dowry demand, the short duration of the marriage, the prolonged nature of the legal proceedings, and the fact that both parties had moved on in life. The court also considered the appellant’s offer to provide community service in the field of information technology, which was noted as a special reason for imposing a sentence of less than six months under the proviso to Section 4 of the DP Act.

Fact:Law Ratio

Logical Reasoning:

The Court’s reasoning was based on a comprehensive analysis of the evidence, the legal provisions, and the circumstances of the case. The court emphasized the need to balance justice with the practical realities of the situation, considering the prolonged legal battle and the fact that both parties had moved on in life. The decision to reduce the sentence and direct compensation was influenced by the principle of proportionality and the desire to provide some measure of redress to the complainant.

The Court quoted from the judgment: “We are satisfied that the ingredients of Section 498 -A of IPC are fully satisfied and that the appellant subjected PW -4 to harassment with a view to coercing her and her mother to meet the unlawful demand for the gold sovereigns and continued to harass her when PW -4 and her relatives failed to meet such demand.”

The Court further quoted: “On the special facts of the case, we think the ends of justice will be met if we adopt the course followed by this Court in the case of Sama ul Sk. vs. The State of Jharkhand & Anr. (2021 INS C 429).”

The Court also noted, “Admittedly, the incident pertains to the year 2006. The marriage was solemnized on 31.03.2006 and the couple lived together exactly for three days. As noticed from the High Court order, the de facto complainant is married and settled abroad. The case has been prolonged for a period of nearly 19 years. Both the appellant and PW-4 have moved on in life.”

Key Takeaways

• The Supreme Court upheld the conviction under Section 498A of the IPC and Section 4 of the DP Act, emphasizing that dowry harassment is a serious offense.
• The Court reduced the sentence to the period already undergone, considering the specific facts of the case, including the short duration of the marriage and the long legal battle.
• The Court directed the appellant to pay compensation of Rs. 3,00,000 to the complainant, recognizing the harassment she endured.
• This judgment highlights the importance of considering both the severity of the offense and the specific circumstances of each case when determining sentencing.

Directions

The Supreme Court directed the appellant to deposit Rs. 3,00,000 in the 4th Metropolitan Magistrate Court, Saidapet, Chennai, within four weeks. This amount is to be paid as compensation to PW-4 Sridevi. The Trial Court was instructed to disburse the amount to PW-4 after due identification. Compliance with this direction must be reported to the Supreme Court within six months.

Development of Law

The ratio decidendi of this case is that while convictions for dowry harassment under Section 498A of the IPC and Section 4 of the DP Act can be upheld based on strong evidence, the sentencing should be tailored to the specific facts of each case, including the duration of the marriage, the time spent in custody, and the overall context of the proceedings. This case also reinforces the principle of providing compensation to victims of harassment.

Conclusion

In summary, the Supreme Court upheld the conviction of the appellant under Section 498A of the IPC and Section 4 of the DP Act, finding sufficient evidence of dowry harassment. However, considering the unique circumstances of the case, including the short duration of the marriage, the time already spent in custody, and the prolonged nature of the legal proceedings, the Court modified the sentence to the period already undergone and directed the appellant to pay Rs. 3,00,000 as compensation to the complainant. This judgment underscores the importance of addressing dowry harassment while also considering the specific context of each case when determining the appropriate sentence.