The Aurangabad bench of the Bombay High Court overturned a 2004 conviction of a man and his family for cruelty and abetment to suicide in connection with the death of his wife.

The Court held that the allegations—such as not allowing the deceased to watch television, preventing her from visiting the temple alone, and making her sleep on a carpet—did not amount to cruelty under Section 498A of the Indian Penal Code (IPC) due to a lack of severity.

The Single-Bench of Justice Abhay S. Waghwase, delivering the October 17 Judgment, stated that the complaints were related to domestic matters and lacked the “severe” nature required to constitute mental or physical cruelty under IPC Section 498A.

The Trial Court in Jalgaon had convicted the accused family members of both cruelty (Section 498A) and abetment to suicide (Section 306) after the woman reportedly committed suicide in 2003. The High Court examined allegations of taunting, late-night water-fetching due to village water supply schedules, and restrictions on social interactions, finding these insufficient to establish a persistent pattern of cruelty.

The prosecution argued that the alleged mistreatment pushed the deceased to take her life; however, the Court found no direct evidence of mistreatment immediately preceding the suicide.

The Bench said, “..above reproduced allegations would not constitute offence of 498A IPC. Humiliation in what form, is not clarified. Merely sleeping on carpet also would not amount to cruelty. Similarly, what sort of taunting was made and by which accused is not getting clear. Likewise, preventing her to mix with neighbour also cannot be termed as harassment….cruelty can be either mental or physical. It is difficult to straitjacket the term cruelty by means of a detenition because cruelty is a relative term. What constitutes cruelty for one person may not constitute cruelty for another person.”

The Court further observed that there had been no contact or complaints from the deceased in the two months prior to her death.

“Here, what is emerging on scrutiny of evidence of mother, uncle and aunt is that, visit of to them was at the time of Holi festival, which falls in March. Incident of suicide is of 01.05.2003. There is a gap of almost two months since deceased, complainant, and witnesses met each other. They have admitted that, there was no communication from either written or oral, she has not conveyed that there was any instances of cruelty in proximity to suicide,” the Court said. 

While quashing the conviction, the Court underscored that domestic disputes without severity or consistent abuse do not meet the threshold of cruelty or harassment necessary for conviction under the relevant IPC sections.

“Consequently, Endings of trial court are patently erroneous. Here, as submitted allegations are non specific, general or petty in nature, essential ingredients for 306 IPC are also not available, and therefore, such Judgment cannot be allowed to be sustained,” the Court ordered.