Calling one's wife “stupid” and “useless” cannot, by itself, amount to cruelty under Section 498A of the Indian Penal Code, the Supreme Court held on Monday, November 2, while quashing the dowry-death and cruelty proceedings against Piyush Narlawar, whose wife died by suicide in Toronto, Canada, in 2023. A bench of Justice B.V. Nagarathna and Justice Manmohan said such remarks, even if accepted at face value, cannot be equated with criminal intimidation or grievous hurt so as to make a husband criminally liable for his wife's suicide, particularly where supporting material is absent, Live Law reported.
Source: Live Law
The couple married on January 3, 2021 and moved to Toronto in February 2022. The woman died on June 11, 2023. Her father then lodged FIR No. 212/2023 at Satara Police Station in Aurangabad on June 30, 2023, under Sections 304B, 323, 498A and 504 read with Section 34 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act. The FIR alleged — as allegations, which the Court ultimately found unsubstantiated — demands including 15 tolas of gold before the marriage, gold ornaments at the first Diwali, Rs 1,00,000 from the woman's brother, and verbal abuse, Law Trend reported.
Source: Law Trend
On the dowry allegations, the bench observed that from the marriage until the death on June 11, 2023, there was “not even a whiff of allegation regarding any demand for dowry” by Narlawar or his family, and that the allegations related to 2021 and 2022 while the FIR was lodged only after the death, which “leaves considerable room for doubt and suspicion”. The Court held that the 15 tolas of gold were given to both the appellant and the deceased as a wedding gift and could not be construed as dowry.
“At best, it reflects on the temperament of the husband, but it cannot be given a criminal colour so grave as to become the reason for the suicide of his wife,” the bench said of the verbal-abuse allegation. “The term 'cruelty' cannot be established without specific instances of commission or omission,” it added, describing the allegations under Sections 323, 498A and 504 as vague and omnibus, with no specific instances of harassment described.
The Court also relied on the Canadian record: the coroner's investigation statement and the Toronto Police closure report of 2024 found no signs of struggle or foul play. The Bombay High Court's Aurangabad Bench had earlier quashed the FIR against Narlawar's parents and sister but refused him relief; a chargesheet followed and non-bailable warrants were issued against him on February 4, 2025. On August 11, 2025, the Supreme Court directed that no coercive steps be taken against him while his appeal was pending.
Applying the categories laid down in State of Haryana v. Bhajan Lal for quashing an FIR, the bench set aside the High Court's order dated January 8, 2025 and quashed FIR No. 212/2023 and all consequent proceedings against Narlawar, holding that allowing the prosecution to continue would be an abuse of the process of law. The case was Criminal Appeal arising out of SLP (Crl.) No. 12158 of 2025, Piyush Narlawar v. State of Maharashtra and Others.
The judgment adds to a line of Supreme Court rulings insisting that Section 498A — now Sections 85 and 86 of the Bharatiya Nyaya Sanhita — requires specific, proximate allegations rather than general claims, while leaving genuine cruelty and dowry-death prosecutions, where evidence supports them, untouched. Sources: Live Law; Law Trend; Law Chronicle.