SC Emphasizes Justice Over Vendetta in Criminal Proceedings

SC Emphasizes Justice Over Vendetta in Criminal Proceedings

On Thursday, the Supreme Court emphasized that the primary objective of criminal proceedings is to ensure that wrongdoers are brought to justice, rather than seeking revenge or pursuing personal vendettas.

A bench of Justices JK Maheshwari and Sanjay Karol made this observation while hearing a criminal breach of trust case involving Padala Veerabhadra Rao from Telangana, who has accused his daughter's former in-laws of failing to return the 'streedhan' given during the marriage.

The term 'streedhan' indeed refers to the gifts, including money and property, given to a woman by her parents, relatives, or in-laws.

The bench reiterated the established legal principle that a woman (whether a wife or former wife) has the exclusive right and authority over her 'streedhan.'

In the criminal case filed by Mr. Rao against his daughter’s former in-laws, the bench emphasized that the goal of criminal proceedings is to bring wrongdoers to justice and not to seek revenge or settle personal grudges. Mr. Rao claimed that he had given gold ornaments and other gifts at his daughter's wedding in 1999, after which the couple moved to the USA. He alleged that his daughter suffered severe mistreatment in the US, which led to his wife's severe distress and eventual death on June 6, 2008.

According to Mr. Rao’s complaint, his daughter and son-in-law divorced on August 14, 2015, after 16 years of marriage. Mr. Rao lodged an FIR in 2021, alleging that the jewellery he had gifted and entrusted to his daughter’s in-laws was not returned. His daughter remarried in 2018. The FIR was registered under Section 406 IPC for criminal breach of trust.

The bench stated that jurisprudence, as developed by the Supreme Court in such cases, clearly affirms that the "singular right" to 'streedhan' belongs exclusively to the female, whether she is a wife or former wife, making her the sole owner.

"It has been held that a husband has no right, and it has to then be necessarily concluded that a father too, has no right when the daughter is alive, well, and entirely capable of making decisions such as pursuing the cause of the recovery of 'stridhan'," Justice Karol, who penned the verdict on behalf of the bench, said.

The court observed that the action to recover the 'streedhan' was initiated more than 20 years after the marriage and five years after the divorce settlement, and notably, it was Mr. Rao, not his daughter, who brought the complaint. The court questioned the basis of these proceedings, given that there was no authorization from Mr. Rao's daughter allowing him to initiate such action for the recovery of her exclusive 'streedhan.'

After reviewing the case materials, the bench found no evidence to support Mr. Rao's claim that he had entrusted his daughter’s 'streedhan' to her former in-laws, which he alleged was wrongfully retained by them.

"In view of the above, we also hold that the charge under Section 6 of the Dowry Prohibition Act is not made out and therefore, fails. Consequently, the only conclusion that can be drawn is that the proceedings initiated by the complainant against the present appellants (former in-laws) have to be quashed and set aside. "Any action commenced as a result thereof is bad in law. The questions raised in this appeal are answered accordingly," the bench said in its order.

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