Order: https://lawyerslibrary.in/books/vlom/
Citation: 2025 INSC 536
Court: Supreme Court of India
Bench: Hon’ble Mr. Justice Surya Kant, Hon’ble Mr. Justice Nongmeikapam Kotiswar Singh
Case Number: Writ Petition (Civil) No. of 2025 (Diary No. 2152/2025); April 15, 2025
Parties: Janshruti (People’s Voice) v. Union of India
Section 498A, Domestic Violence, Dowry, Constitutional Validity, Article 14, Article 15, Misuse of Law, Gender-Specific Legislation
Writ petition under Article 32 seeking gender-neutral guidelines for domestic violence complaints and declaration on the constitutionality of Section 498A, IPC (now Section 84, Bharatiya Nyaya Sanhita, 2023) dismissed. Court held that Section 498A, enacted to combat dowry-related cruelty against women, does not warrant judicial interference as it is constitutionally sound, supported by legislative intent under Article 15, and addresses a persistent social evil. Allegations of misuse do not render the provision invalid; such claims require case-by-case assessment. The provision remains a vital safeguard for vulnerable women, and no violation of Article 14 was found.
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Facts
The petitioner, Janshruti (People’s Voice), filed a writ petition under Article 32 of the Constitution of India, seeking: (1) formulation of gender-neutral guidelines and legislation for domestic violence and harassment complaints, and (2) a declaration on the constitutionality of Section 498A of the Indian Penal Code, 1860 (now Section 84, Bharatiya Nyaya Sanhita, 2023). The petitioner argued that the provision was misused and violated Article 14 (equality before law). The petition was heard after condoning a delay in filing.
Issues
- Whether Section 498A, IPC, is constitutionally invalid or requires judicial intervention due to alleged misuse.
- Whether gender-neutral guidelines for domestic violence complaints should be mandated.
- Whether the provision violates Article 14 of the Constitution.
Held
The Supreme Court dismissed the writ petition, declining to grant the requested reliefs. Key findings include:
- Constitutional Validity of Section 498A: The Court held that Section 498A, enacted in 1983 to address dowry-related cruelty and exploitation of married women, is constitutionally sound. It is supported by the legislative intent under Article 15, which permits positive discrimination for women and other vulnerable groups. The provision addresses a persistent social evil and does not warrant judicial interference unless it lacks reasonable justification, is mala fide, lacks rational nexus, or violates constitutional rights—none of which were established.
- Allegations of Misuse: The Court acknowledged instances of misuse but held that such occurrences do not render the provision invalid. Misuse must be addressed on a case-by-case basis by appropriate judicial forums, as these cases involve complex factual circumstances. The Court emphasized that the possibility of misuse does not justify striking down or diluting a law, citing precedent (Sushil Kumar Sharma v. Union of India, AIR 2005 SC 3100).
- Continued Relevance: The Court noted the persistent prevalence of dowry and unreported domestic cruelty, underscoring the necessity of Section 498A as a vital safeguard for vulnerable women. It rejected the argument that the provision violates Article 14, finding the petitioner’s claims vague and unsubstantiated.
- Separation of Powers: The Court declined to interfere with legislative policy, respecting the doctrine of separation of powers and the Legislature’s wisdom in retaining the provision.
- Gender-Neutral Guidelines: The Court did not entertain the request for gender-neutral guidelines, finding no justification to alter the existing framework given the provision’s protective purpose.
Ratio Decidendi
Section 498A, IPC, is constitutionally valid as it serves a legitimate objective of protecting women from dowry-related cruelty, a pervasive social issue. The mere possibility of misuse does not justify judicial interference, and such claims require case-specific adjudication. The provision aligns with Article 15’s principle of positive discrimination and does not violate Article 14.
Obiter Dicta
The Court expressed concern over public acts (e.g., videos depicting dowry exchanges) that undermine the law’s purpose and highlighted the unreported nature of many dowry-related cases, reinforcing the need for protective legal provisions.
Disposition
The writ petition was dismissed, and all pending applications were disposed of. No relief was granted to the petitioner.
Counsel
- For Petitioner(s) :Ms. Shashi Kiran, Sr. Adv. Ms. Sadhana Sandhu, AOR Dr. Satish Chandra, Adv. Ms. Sangeeta Bhalla, Adv. Ms. Ashna Singh, Adv. Mr. Vishal Singh Chandel, Adv. Ms. Anju Sen, Adv
Key Precedent Cited:
- Sushil Kumar Sharma v. Union of India, AIR 2005 SC 3100 (on misuse of Section 498A).
Significance
The judgment reaffirms the constitutional validity of Section 498A, emphasizing its role in combating dowry-related violence while clarifying that misuse does not negate its necessity. It underscores the judiciary’s restraint in interfering with legislative policy and the importance of case-specific assessments for misuse claims.
Multiple Choice Questions (MCQs)
- What was the primary relief sought by the petitioner in Janshruti (People’s Voice) v. Union of India, 2025 INSC 536?
a) Repeal of Article 14 of the Constitution
b) Formulation of gender-neutral guidelines for domestic violence complaints and declaration on the constitutionality of Section 498A, IPC
c) Mandatory compensation for misuse of dowry laws
d) Ban on dowry-related prosecutions
Correct Answer: b) Formulation of gender-neutral guidelines for domestic violence complaints and declaration on the constitutionality of Section 498A, IPC - Under which article of the Constitution was the writ petition filed?
a) Article 14
b) Article 15
c) Article 32
d) Article 226
Correct Answer: c) Article 32 - What was the Supreme Court’s stance on the constitutionality of Section 498A, IPC?
a) It declared the provision unconstitutional due to misuse.
b) It upheld the provision as constitutionally valid, serving a legitimate purpose.
c) It struck down the provision for violating Article 14.
d) It directed the Legislature to repeal the provision.
Correct Answer: b) It upheld the provision as constitutionally valid, serving a legitimate purpose. - According to the Court, under what circumstances would judicial interference in legislative provisions be warranted?
a) If the provision is widely criticized in public discourse
b) If the provision is devoid of reasonable justification, mala fide, lacks rational nexus, or violates constitutional rights
c) If the provision is outdated by more than 20 years
d) If the provision is misused in more than 50% of cases
Correct Answer: b) If the provision is devoid of reasonable justification, mala fide, lacks rational nexus, or violates constitutional rights - What constitutional principle did the Court cite to justify Section 498A’s gender-specific nature?
a) Equality before law under Article 14
b) Positive discrimination under Article 15
c) Right to life under Article 21
d) Freedom of speech under Article 19
Correct Answer: b) Positive discrimination under Article 15 - How did the Court address the issue of misuse of Section 498A?
a) It declared the provision invalid due to widespread misuse.
b) It held that misuse does not render the provision unconstitutional and requires case-by-case assessment.
c) It mandated gender-neutral amendments to prevent misuse.
d) It directed the police to stop registering cases under Section 498A.
Correct Answer: b) It held that misuse does not render the provision unconstitutional and requires case-by-case assessment. - What was the Court’s observation regarding dowry as a social issue?
a) Dowry is no longer prevalent in Indian society.
b) Dowry remains a deeply entrenched social evil, with many cases unreported.
c) Dowry-related issues are adequately addressed by existing laws other than Section 498A.
d) Dowry cases are primarily due to misuse of legal provisions.
Correct Answer: b) Dowry remains a deeply entrenched social evil, with many cases unreported. - What precedent was cited by the Court in relation to Section 498A?
a) Vishaka v. State of Rajasthan
b) Sushil Kumar Sharma v. Union of India
c) Maneka Gandhi v. Union of India
d) Kesavananda Bharati v. State of Kerala
Correct Answer: b) Sushil Kumar Sharma v. Union of India
Frequently Asked Questions (FAQs)
- What was the main objective of the writ petition in Janshruti (People’s Voice) v. Union of India?
The petition sought directions for formulating gender-neutral guidelines and legislation for domestic violence and harassment complaints. It also challenged the constitutionality of Section 498A, IPC (now Section 84, Bharatiya Nyaya Sanhita, 2023), alleging it was misused and violated Article 14 (equality before law). - Why did the Supreme Court dismiss the writ petition?
The Court dismissed the petition because it found Section 498A to be constitutionally valid, serving the legitimate purpose of protecting women from dowry-related cruelty. It held that the provision aligns with Article 15’s principle of positive discrimination, and allegations of misuse do not justify striking it down. The Court also respected the doctrine of separation of powers and found the petitioner’s claims vague. - What is Section 498A, IPC, and why was it enacted?
Section 498A, IPC, was introduced in 1983 to address cruelty and harassment faced by married women, particularly due to dowry demands. It was enacted to combat the pervasive social issue of dowry-related exploitation, which often led to severe abuse and suffering. - How did the Court address concerns about the misuse of Section 498A?
The Court acknowledged instances of misuse but clarified that such cases do not render the provision unconstitutional. It emphasized that misuse should be addressed on a case-by-case basis by appropriate judicial forums, as these cases involve complex factual circumstances. - What role did Article 15 of the Constitution play in the Court’s reasoning?
The Court relied on Article 15, which allows the state to make special provisions for women and other disadvantaged groups. It held that Section 498A’s gender-specific nature is justified as a form of positive discrimination to protect vulnerable women from systemic abuse. - Did the Court comment on the prevalence of dowry in India?
Yes, the Court noted that dowry remains a deeply entrenched social evil, with many cases going unreported. It highlighted the continued need for provisions like Section 498A to protect women who endure such injustices in silence. - Why did the Court refuse to formulate gender-neutral guidelines?
The Court found no justification to alter the existing framework of Section 498A, given its protective purpose and legislative intent. It prioritized the provision’s role in safeguarding women over the petitioner’s demand for gender-neutral guidelines. - What was the Court’s stance on judicial interference in legislative matters?
The Court reiterated that it refrains from interfering in legislative policy unless a provision is devoid of reasonable justification, mala fide, lacks rational nexus with its objective, or violates constitutional rights. In this case, none of these conditions were met. - What precedent was referenced in the judgment?
The Court cited Sushil Kumar Sharma v. Union of India (AIR 2005 SC 3100), which held that while misuse of Section 498A must be guarded against, the provision’s importance cannot be undermined due to occasional unscrupulous use. - What broader societal observations did the Court make?
The Court expressed concern over public acts, such as videos depicting dowry exchanges, which undermine the law’s purpose. It also emphasized its responsibility as a constitutional court to safeguard justice for all, particularly for vulnerable women facing unreported dowry-related cruelty.