In a recent judgment, the Allahabad High Court addressed marital obligations and sexual compatibility between spouses. The court posed a thought-provoking question, observing, "If a husband and wife do not seek sexual intimacy from each other, where will they fulfill such needs within a morally civilized society?"
The bench, led by Justice Anish Kumar Gupta, was hearing an application under Section 482 of the CrPC, filed by a man seeking to quash criminal proceedings initiated by his father-in-law. The case involved allegations of cruelty, including physical and emotional abuse, unnatural sexual demands, and dowry harassment, filed under Sections 498-A, 323, 504, 506, and 509 of the IPC, along with Section 3/4 of the Dowry Prohibition Act.
Upon reviewing the evidence, the court found that the primary issue between the couple was sexual incompatibility, rather than dowry-related disputes. The wife had accused her husband of abusive behavior, particularly under the influence of alcohol and drugs, including coercion into unnatural sexual acts. However, the court noted a lack of specific evidence of dowry demands or concrete incidents of dowry harassment either before or during the marriage.
The court emphasized that sexual relations are a natural part of marriage, and dissatisfaction or refusal alone cannot be classified as criminal unless there is substantial proof of cruelty or harassment. Additionally, despite allegations of physical abuse linked to sexual demands, no medical records or evidence of injuries were produced to support these claims.
Consequently, the court found the allegations vague and lacking the specificity required to prosecute under Section 498-A, which deals with cruelty towards a woman by her husband or his family. It opined that the FIR appeared to be based on exaggerated claims, with false accusations of dowry harassment stemming from the couple's personal differences over sexual incompatibility.
Highlighting the trend of false or exaggerated claims in matrimonial disputes, the court urged caution in pursuing criminal trials based solely on general allegations. Ultimately, the court quashed the case, ruling that the FIR was a concocted story of dowry demands and harassment, and allowed the man's application to dismiss the charges against him and his family.
Case Title: Pranjal Shukla And 2 Others Vs. State of U.P. and Another
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