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Couple Living Together Under 'Marriage Agreement' Not Husband-Wife, No Prosecution U/S 498A IPC:

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The Kerala High Court has acquitted a

man and his family who were convicted

under Section 498A IPC for cruelty

against a deceased woman on the

finding that the parties were living

together as husband and wife, based on

a marriage agreement and their

marriage was not solemnized.

The deceased and 1st revision petitioner

eloped and they were living together as

husband and wife based on a marriage

agreement. Due to alleged il-treatment

from the man's family, the deceased

attempted suicide by self-immolation

using kerosene and succumbed to her

burn injuries. The Trial Court convicted

the man and family under Sections

498A, 306 IPC and the conviction was

upheld by the Appellate Court. The

revision petitioners thus approached the

High Court.

The Court on examining the validity of

the conviction found that no evidence

was brought on record to show that the

marriage between the 1st revision

petitioner and deceased were

solemnized under any form of marriage

either religious or customary. The Court

found that they were living together as

husband and wife based on a marriage

agreement which has no legal sanctity.

The Court found that even if the

marriage agreement was registered, it

cannot be replaced for a legally valid

marriage. Thus, the Court found that

they were living together as husband

and wife without a valid marriage

document. The Court found that a

woman can seek legal recourse under

Section 498A IPC only when there was a

legally valid marriage between the

parties.

The Court relied upon Reema Aggarwal

vs. Anupam and others (2004) to state

that the expression 'husband' under

Section 498A IPC would only covera

person who enters into a marital

relationship. It also relied upon

Shivcharan Lal Verma and another vs.

State of Madhya Pradesh (2007) to state

that there must be a valid marital

relationship between the accused and

the victim for attracting an offence

under Section 498 A IPC. The Court held

that only a legally wedded wife can

prosecute her husband for cruelty under

Section 498A IPC. The Court also relied

upon Unnikrishnan vs. State of Kerala

(2017) and Suprabha vs. State of Kerala

(2013) to state that valid marriage was

essential for prosecuting under Section

498A IPC and live in relationship was

not sufficient to attract an offence of

cruelty.

The Court found that the dying

declaration of the deceased stated that

the 1s revision petitioner was a loving

husband and it was the family members

who ill-treated her. The Court also noted

that there were no specific allegations

made against the family, except general

allegations of mistreatment. It also

found that the conviction under Section

306 IPC for abetment of suicide was not

sustainable because there was nothing

to show that the 1st and 4th revision

petitioner did any positive act for

abetting her suicide. It found that the

allegations were mostly against the

parents, 2nd and 3d revision petitioners,

who were no more.

The Court relied upon M.Mohan vs.

State represented by the Deputy

Superintendent of Police (2011) and

Rajesh vs. State of Haryana (2019) to

state that conviction cannot be made

under Section 306 IPC without a positive

action of harassment on the part of the

under Section 306 IPC without a positive

action of harassment on the part of the

accused to instigate or aid in

committing suicide.

The Court found that the prosecution

was unsuccessful in proving the

offences of cruelty or abetment to

suicide against the revision petitioners

beyond reasonable doubt. Thus, the

Court allowed the criminal revision

petition and set aside the conviction of

the 1st and 4th revision petitioner and

ordered their release from the prison.

JaiHind.. JaiBharat..


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