Mother-In-Law Objecting To Household Works Of Daughter-In-Law Doesn't Constitute Cruelty U/S 498-A IPC: Madhya Pradesh High Court
In a recent ruling, the Madhya Pradesh High Court has said that the mere act of a mother-in-law objecting to the household work of her daughter-in-law does not constitute cruelty under Section 498-A IPC."If the daughter-in-law gets mental harassment on account of certain objections raised by her mother-in-law in the household works, then it can be said that the daughter-in-law may...
In a recent ruling, the Madhya Pradesh High Court has said that the mere act of a mother-in-law objecting to the household work of her daughter-in-law does not constitute cruelty under Section 498-A IPC.
"If the daughter-in-law gets mental harassment on account of certain objections raised by her mother-in-law in the household works, then it can be said that the daughter-in-law may be hypersensitive. But, certain disputes with regard to household works would certainly not amount to cruelty," a bench of Justice Gurpal Singh Ahluwalia observed.
The single judge added that if a mother-in-law tries to stay away from the personal disputes in the life of the husband and wife, then also it cannot be said that such an act of mother-in-law would amount to cruelty as per the requirement of Section 498A IPC.
The court made these observations while allowing a plea filed by one Alka Sharma (mother-in-law) seeking quashing of FIR and subsequent proceedings in a case lodged against her (filed by her daughter-in-law) for the offences under Sections 498-A, 506 r/w Section 34 of IPC and Section 3, 4 of Dowry Prohibition Act.
The facts, in brief, are as follows: At the time of marriage, the applicant (mother-in-law) was employed and stationed in Chakhrata, Uttarakhand. However, four months into the marriage between respondent no. 2 (daughter-in-law) and her son/husband, the applicant opted for voluntary retirement and relocated to Pune, where they all began residing together.
As per the allegations levelled by the daughter-in-law, her mother-in-law (applicant) started interfering in household matters upon moving in and her husband began siding with the applicant. It was alleged that the applicant frequently mentioned astrological predictions indicating two marriages for respondent no. 2, causing mental distress to her.
Additionally, when respondent no. 2 faced public humiliation from her husband, the applicant, her mother-in-law, allegedly did not intervene or support her, exacerbating the situation.
It was the case of the applicant that even if the entire allegations are accepted, then it cannot be said that there was any wilful act/conduct on the part of the applicant which may have driven respondent no. 2 to commit suicide.
Court's observations
Against the backdrop of the facts of the case as well as the submissions advanced by the counsel for the applicant, the Court noted that the objections raised by a mother-in-law regarding the household chores of her daughter-in-law cannot be considered cruelty under Section 498-A of the IPC.
The Court also noted that if a mother-in-law refrains from interfering in personal disputes between the husband and wife, it cannot be deemed cruel behaviour.
Importantly, the Court stressed that the fact that the mother-in-law/applicant had relocated to a foreign country and was living with her daughter and son-in-law undermined the allegation of cruelty.
The court also dismissed the claim of deprivation of love and affection from the mother-in-law as insufficient to constitute cruelty in this case.
In view of this, considering the totality of the facts and circumstances of the case, the Court noted that even if the entire allegations made in the FIR are accepted on their face value, still no offence under Sections 498-A, 506/34 of IPC read with Section 3/ 4 of Dowry Prohibition Act would be made out.
Consequently, the Court allowed the plea and quashed the criminal proceedings against the applicant/mother-in-law.
Case title - Alka Sharma vs. State of Madhya Pradesh and Another
Citation: 2024 LiveLaw (MP) 72