Supreme Court Dismisses Domestic Violence Case for Lack of Prima Facie Evidence

In two connected criminal appeals challenging a Delhi High Court ruling, the Supreme Court Bench of Justices B.V. Nagarathna and Satish Chandra Sharma reinstated the trial court's decision to discharge a husband accused under Section 498-A of the IPC. The Court held that the allegations made by the complainant-wife lacked specificity and credible evidence, failing to establish a prima facie case of cruelty. Supreme Court dismisses this domestic violence case for lack of prima facie evidence.

The case stemmed from a complaint lodged by the wife in 2002 against her husband and his family under Sections 498-A, 406, and 34 of the IPC. She alleged sustained physical and emotional abuse, dowry harassment, and threats, with incidents dating back to 1999. These included claims of being beaten, threatened with a weapon, and forced out of her marital home. Despite these serious charges, the Sessions Court had discharged the accused, citing vague accusations, procedural delay, and lack of supporting evidence—particularly considering the complainant’s background as a trained police officer. The High Court overturned this, calling the lower court’s reasoning flawed.

Upon review, the Supreme Court emphasized that broad and general allegations—particularly against numerous family members including elderly parents-in-law, five sisters-in-law, and even an unrelated tailor—cannot be the basis for criminal prosecution. It underscored the absence of detailed allegations or medical records, rendering the claims insufficient to proceed to trial under Section 498-A.

The Court clarified that the complaint was within the limitation period under Section 468 CrPC, citing precedents like Bharat Damodar Kale and Sarah Mathew, holding that limitation is computed from the date of filing, not cognizance.

While acknowledging that even police officers can be victims, the Court warned against the increasing misuse of criminal law in matrimonial conflicts. Invoking Article 142 of the Constitution, it quashed the FIR and charge sheet, reasoning that prolonging the trial more than 20 years after the alleged incidents would amount to injustice, especially in the absence of concrete evidence.

Case title- [Ghanshyam Soni v. State (NCT of Delhi), Decided on: 04-06-2025]