Rajesh Chaddha vs State of Uttar Pradesh 2025 case gained attention due to the strong stance of the Supreme Court on safeguarding the rights of the accused in matrimonial disputes. It questioned the validity of convictions based on general allegations without concrete proof and highlighted the misuse of dowry laws. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

Rajesh Chaddha vs State of Uttar Pradesh 2025 Introduction

Rajesh Chaddha vs State of Uttar Pradesh 2025 is a landmark judgment of the Supreme Court that dealt with allegations of cruelty and dowry harassment under Section 498A of the Indian Penal Code and Section 4 of the Dowry Prohibition Act, 1961. The case revolved around the conviction of a husband accused of subjecting his wife to physical and mental cruelty shortly after their marriage.

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The case at hand centres around the appeal of an individual convicted under Section 498A of the Indian Penal Code and Section 4 of the Dowry Prohibition Act, 1961. The Appellant, a husband, was accused of subjecting his wife to cruelty and harassment for dowry after their marriage. The following are the facts of Rajesh Chaddha vs State of Uttar Pradesh -

Background of the Case

The appeals before the Supreme Court arose from an order dated 14th November, 2018 passed by the High Court of Allahabad. The High Court of Allahabad upheld the conviction of the Appellant under Section 498A of the Indian Penal Code (IPC) and Section 4 of the Dowry Prohibition Act, 1961. This conviction had earlier been affirmed by the Additional Sessions Judge, Lucknow on 18th November, 2004. The appeal was filed against the judgment dated 28th August, 2004 adjudicated by the Chief Judicial Magistrate, which had acquitted the Appellant of charges under Section 323 r/w Section 34 IPC and Section 506 IPC, but convicted him under Section 498A IPC and Section 4 of the Dowry Prohibition Act. A recall application filed against the judgment of the High Court was also dismissed on 28th November, 2018.

Allegations by the Complainant

The case originated from case crime which was registered based on a complaint dated 20th December, 1999 filed by the complainant-wife, Ms. Mala Chaddha. The complaint was against her husband, Appellant and his family members, alleged cruelty and harassment for dowry. The couple had been married on 12th February, 1997 and had lived together only briefly, from 8th September, 1998 to 20th September, 1998. The complainant alleged that on the advice of the Appellant, she had resigned from her job and her family had spent more than Rs. 5 lakhs on the marriage. She stated that she was subjected to both mental and physical harassment including being forced to drink milk mixed with intoxicants, being coerced into attending late-night parties and ultimately being expelled from her matrimonial home while pregnant. She also contended to have suffered a miscarriage on 10th February, 1998 as a result of physical assault.

Evidence and Testimony

In her statement under Section 164 of Criminal Procedure Code, the complainant reiterated her allegations and added that she was made to work in a school run by her in-laws and surrender her salary. She alleged a demand of Rs. 2 lakhs was made by the accused, and when her parents failed to fulfil it, she was assaulted. Both the complainant and her father testified in court and supported the version of the Prosecution regarding the dowry demands and mistreatment. However, the claim of physical assault which led to miscarriage was not substantiated with medical evidence.

Findings of the Trial Court

The Trial Court found that although there was insufficient medical evidence to establish physical assault and miscarriage, mental cruelty and harassment for dowry were proven. The appellant was convicted and sentenced to two years of rigorous imprisonment and a fine of Rs. 5,000 under Section 498A IPC along with 1 year of rigorous imprisonment and a fine of Rs. 2,000 under Section 4 of the Dowry Prohibition Act.

Decision of the High Court

The Additional Sessions Judge dismissed the appeal against the conviction and found no irregularity in the judgment of the Trial Court. The High Court upheld this decision as well, concluding that the conviction was based on proper evaluation of the evidence and that no legal error or perversity was found in the judgments of the Trial Court. The High Court also dismissed the application seeking recall of its judgment.

Rajesh Chaddha vs State of Uttar Pradesh 2025 Legal Issues

The following issues were addressed in Rajesh Chaddha vs State of Uttar Pradesh 2025 -

• Validity of Conviction Under Section 498A IPC

The first issue addressed in Rajesh Chaddha vs State of Uttar Pradesh case was whether the conviction of the Appellant under Section 498A IPC (Now Section 85 & Section 86 BNS, 2023) was justified. The Supreme Court examined whether the allegations of cruelty made by the complainant met the legal threshold of "cruelty" as defined under Section 498A.

• Proof of Dowry Harassment Under Section 3 and Section 4 of the Dowry Prohibition Act

The case also involved the question of whether the Appellant was guilty of dowry harassment under Section 3 and Section 4 of the Dowry Prohibition Act, 1961. The issue was whether the complainant’s vague allegations of dowry demand and harassment were sufficient to meet the legal requirements for conviction under these provisions.

• Sufficiency of Evidence for Conviction

The Supreme Court in Rajesh Chaddha vs State of Uttar Pradesh also examined another legal issue related to the sufficiency of evidence for the conviction. The Court questioned whether the vague, general and unsubstantiated allegations of cruelty and dowry harassment, unsupported by medical evidence or specific details of incidents, could legally sustain a conviction under Section 498A IPC and Section 4 of the Dowry Prohibition Act.

Section 498A of Indian Penal Code and Section 3 and Section 4 of the Dowry Prohibition Act played an important role in Rajesh Chaddha vs State of Uttar Pradesh 2025. The following are the analysis of these provisions -

Section 498A of the Indian Penal Code

Section 498A (Now Section 85 and 86 of Bharatiya Nyaya Sanhita, 2023) criminalizes the act of cruelty by a husband or his relatives towards a wife. It defines cruelty as any willful conduct that endangers the woman's life, limb, health (mental or physical), or causes harassment with a view to coercing her or her family to meet unlawful demands, including dowry.

In Rajesh Chaddha vs State of Uttar Pradesh the Appellant was convicted under Section 498A IPC for subjecting the complainant to cruelty. The Supreme Court examined the evidence.

Section 3 of the Dowry Prohibition Act, 1961

Section 3 of Dowry Prohibition Act 1961 prohibits both the giving and receiving of dowry. Any individual demanding dowry directly or indirectly shall be punishable with-

• Imprisonment: Up to five years
• Fine: Rs. 15,000 or the equivalent value of the dowry, whichever is higher.

In Rajesh Chaddha vs State of Uttar Pradesh the complainant alleged that dowry demands were made by the appellant and his family.

Section 4 of the Dowry Prohibition Act, 1961

According to Section 4 of Dowry Prohibition Act 1961, any person who demands dowry directly or indirectly from the parents or other relatives or guardian of a bride or bridegroom he shall be punishable with-

• Imprisonment: not be less than six months but which may extend to two years
• Fine: Up to ten thousand rupees

The Appellant in Rajesh Chaddha vs State of Uttar Pradesh was also convicted under Section 4 of the Dowry Prohibition Act for allegedly demanding dowry from the complainant.

Rajesh Chaddha vs State of Uttar Pradesh 2025 Judgment and Impact

On 13th May, 2025, the 2-Judge Bench of the Supreme Court comprising Justice B. V. Nagarathna and Justice Satish Chandra Sharma in Rajesh Chaddha vs State of Uttar Pradesh after examining the facts and legal provisions observed that the definition of "cruelty" under Section 498A IPC involves willful conduct that endangers a life, health, or mental well-being of women including harassment for dowry demands. Similarly, under Section 4 of the Dowry Prohibition Act, both direct and indirect demands for dowry are criminalized.

The Supreme Court noted that the allegations of cruelty and dowry harassment by the Complainant in Rajesh Chaddha vs State of Uttar Pradesh were vague and lacked specifics regarding dates, times and circumstances. The complainant failed to substantiate her claims with concrete evidence such as medical records or specific instances of harassment. Despite claiming to have been physically assaulted and suffering a miscarriage, no medical documents were produced to verify these allegations.

The Trial Court had acquitted the Appellant of charges under Section 323 and Section 506 IPC (Now Section 351 BNS) but convicted him under Section 498A IPC and Section 4 of the Dowry Prohibition Act based on the uncorroborated testimonies of the complainant and her father. The Supreme Court in Rajesh Chaddha vs State of Uttar Pradesh found that the conviction under these sections was not supported by sufficient evidence or material facts. Additionally, the Court observed that the FIR was filed after the appellant had filed for divorce which raised questions about the credibility of the allegations.

The High Court while exercising revisionary jurisdiction failed to critically examine the materials on record. The Supreme Court noted that such vague allegations should not have resulted in a conviction and the revisionary powers should have been exercised more prudently to prevent the abuse of legal provisions in matrimonial disputes.

The Supreme Court in Rajesh Chaddha vs State of Uttar Pradesh referred to Dara Lakshmi Narayan vs State of Telangana expressed concern over the growing tendency to implicate not only the husband but also his family members such as parents and distant relatives, in cases of marital disputes without any specific allegations against them. This practice, the Court noted, undermines the purpose of protective legislation like Section 498A IPC and the Dowry Prohibition Act.

On the basis of the above findings, the Supreme Court in Rajesh Chaddha vs State of Uttar Pradesh allowed the appeal, set aside the order of the Allahabad High Court of convicting the appellant and acquitted him of all charges. The Court highlighted that any further prosecution in this case would constitute an abuse of the legal process, especially since the marriage had already been dissolved and the divorce decree had attained finality.

Thus, in Rajesh Chaddha vs State of Uttar Pradesh, the Supreme concluded by dismissing the appeal and relieving the appellant of the charges and reasoned that the complaint lacked the necessary specificity and evidence to sustain the conviction.

Conclusion

In Rajesh Chaddha vs State of Uttar Pradesh 2025 the Supreme Court on 13th May, 2025 acquitted the appellant and held that vague and unsubstantiated allegations could not justify a conviction. The judgment reinforced the need for specific, credible evidence in matrimonial dispute cases and cautioned against the misuse of protective legal provisions.