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News Citation : 2026 LN (HC) 327 | 2026:JHHC:13377
May 5, 2026 : The Jharkhand High Court has quashed criminal proceedings against a couple accused in a dowry harassment case, holding that the allegations made against them did not satisfy the essential ingredients required to constitute an offence under Section 498A of the Indian Penal Code.
Justice Anil Kumar Choudhary passed the order while hearing a criminal miscellaneous petition filed by Ram Lakhan Ram and his wife Panpati Devi, who had sought quashing of proceedings arising out of Complaint Case No. 1397 of 2021 pending before a Judicial Magistrate in Palamau.
The complaint had also named their son, Manoj Ram alias Manoj Kumar, against whom the trial court had found a prima facie case under Sections 498A, 354 and 506 IPC. However, during the hearing before the High Court, counsel for Manoj Ram withdrew the quashing plea with liberty to raise all grounds before the appropriate court at a later stage.
According to the complaint, the allegations against the elderly couple were limited to taunting the complainant after the death of her husband by allegedly saying that she had “eaten up” her husband and compelling her to perform household chores. Counsel for the petitioners argued that even if these allegations were accepted in entirety, they did not amount to cruelty as defined under Section 498A IPC.
The State and the complainant opposed the plea, contending that the statements made in the complaint and during inquiry disclosed a prima facie offence.
After examining the records, the High Court observed that there were no allegations suggesting that the couple engaged in wilful conduct likely to drive the complainant to commit suicide or cause grave injury to her mental or physical health. The Court also noted the absence of any accusation that the couple harassed the complainant to coerce fulfilment of an unlawful demand.
Holding that continuation of criminal proceedings against the couple would amount to abuse of the process of law, the Court quashed the entire criminal proceeding and the magistrate’s order dated November 11, 2022, insofar as it related to the two petitioners. The petition was accordingly allowed in part.
Case Reference : Cr.M.P. No. 247 of 2023, Ram Lakhan Ram & Ors. vs The State of Jharkhand & Anr.; Appearance: Mr. Amit Kumar Das, Advocate for the Petitioners, Mr. Vineet Kr. Vashistha, Spl. P.P. for the State, and Mr. Sheo Kumar Singh, Advocate for O.P. No. 2.