The Madhya Pradesh High Court in its order dated March 14, 2024 quashed a case of 498-A against a mother-in-law, accused of meddling in household chores with daughter-in-law.
The High Court held that such day-to-day objections raised by mother-in-law cannot be deemed as cruelty to her daughter-in-law.
Case:
Respondent No. 2 (daughter-in-law) got married to Respondent No. 1 (mother-in-law)’s son in April 2016 at Jabalpur, Madhya Pradesh.
This was a love marriage attended by family members from both sides. At the time of marriage, the mother-in-law was working in Uttarakhand, however, after four months, she took voluntary retirement and shifted to Pune to reside with her son and daughter-in-law.
In 2021, the daughter-in-law filed an FIR against her husband and mother-in-law at the Mahila Police Thana in Jabalpur under Sections 498-A, 506 r/w Section 34 of IPC and Section 3, 4 of Dowry Prohibition Act.
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Allegations by Daughter-in-Law
According to Respondent No. 2, her mother-in-law started interfering in her day-to-day life and was abusive which affected her mentally. She claimed that her husband too, sided with his mother.
The daughter-in-law alleged that her mother-in-law was unhappy with their marriage and her husband would regularly demand dowry in the form of car and flat. She informed court that she would spend from her own savings to purchase expensive household items for the home, as demanded by her husband.
Though this was a love marriage, the daughter-in-law also accused her husband of being impotent, as she did not conceive for seven months post marriage.
Further, she claimed that after her mother-in-law went to reside in the US with her daughter and son-in-law, her husband too, could leave the country for good, spoiling her life. Thus, she asked the court to seize his passport.
The daughter-in-law also accused her husband of speaking to other women frequently over the phone, and pressurising her to leave him. Adding further, she accused the mother-in-law of not intervening between the couple to clear differences or attempt a reconciliation between husband and wife.
Subsequently, she filed an FIR against her husband and mother-in-law.
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Defense by Mother-in-Law
The mother-in-law challenged the FIR and submitted that even if the entire allegations are accepted on their face value, then no offence would be made out warranting prosecution of the applicant.
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Madhya Pradesh High Court
The bench of Justice Gurpal Singh Ahluwalia analysed the allegations on record and made observations step by step. With regards to the interference of household chores, Justice Ahluwalia said:
If mother-in-law was objecting to certain household works of her daughter-in-law, then by no stretch of imagination it can be said that such act of the mother-in-law would fall within the category of cruelty as defined under Section 498-A of IPC.
Adding further, the High Court noted:
If daughter-in-law gets mental harassment on account of certain objections raised by her mother-in-law in the household works, then it can be said that daughter-in-law may be hypersensitive. But, certain disputes with regard to household works would certainly not amount to cruelty as cruelty.
Additionally, the bench noted that the allegation of the mother-in-law’s non-intervention in disputes between her son and daughter-in-law does not amount to cruelty, particularly if she chose to refrain from involvement in their personal matters.
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The High Court also observed that the mother-in-law had relocated to the US and was residing with her daughter and son-in-law, which signified a physical separation from the matrimonial dispute between her son and daughter-in-law.
Justice Ahluwalia added:
A bald allegation that daughter-in-law was deprived of love and affection of her mother-in-law would also not amount to cruelty. Although said fact, if considered along with other circumstances may become important but in the facts and circumstances of the case, the aforesaid allegation would not amount to cruelty.
Lastly, the High Court expressed that even if all the allegations in the FIR were accepted at face value, no offences under Sections 498-A, 506/34 of IPC read with Section 3/4 of the Dowry Prohibition Act would be established.
Accordingly, the FIR against the mother-in-law was quashed.
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READ ORDER | Mother-In-Law Interfering In Household Work Doesn't Amount To Cruelty Against Daughter-In-Law u/s #498A IPC: Madhya Pradesh High Court#VoiceForMen https://t.co/HjwoN191Qc
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