CITATION | 2022 SCC Online SC 31 |
DATE OF JUDGEMENT | 11th Jan 2022 |
COURT | Supreme Court of India |
APPELANT | Meera |
RESPONDENT | State by Inspector of Police, Thiruvotriyur Police Station, Chennai |
BENCH | Justice M.R .Shah, Justice B.V. Nagarathna |
CASE NO. | Appeal no. 31 of 2022 |
CASE TYPE | Criminal Appeal |
STATUTES REFERRED | Section 498A and Section 306 of Indian Penal Code, 1860Section 313 of Code of Criminal Procedure,1973 |
INTRODUCTION
The Supreme Court noted that “how cruelty dedicated via one lady towards another girl ends in an extra critical offence” in the aforementioned situation. The mother-in-law’s conviction under section 498A of the Indian Penal Code was also upheld by the court order. This highlights how important it is for a girl to defend the rights of other girls instead of taking terrible actions against them. Who will stand up for humans if humans no longer do so? This is the core of what makes us human.
The Supreme Court further declared that “The appellant, who became the mother-in-law, ought to have been more understanding of her daughter-in-law because she was a female. An offense becomes more serious when it is committed by a woman who uses cruelty toward any other woman, such as her daughter-in-law. Judges MR Shah and BV Nagarathna constituted a bench and stated, “If a lady, i.e., the mother-in-law herein does not shield any other girl, the other female, i.e., daughter-in-law, could emerge as susceptible.”
FACTS
- According to the case’s facts, it was alleged that the deceased was tormented and mistreated by the appellant and other family members since they had not given any jewellery. Moreover, it was claimed that the deceased committed suicide by setting themselves on fire as a result.
- The Trial Court found the appellant and the other accused people guilty of violating Sections 498A and 306 of the IPC; as punishment, they were sentenced to jail term and fines. The appellant’s conviction under Section 498A IPC was confirmed by the High Court upon appeal, whereas the accused was found not guilty of the charge under Section 306 IPC. This verdict infuriated the appellant, who filed the current appeal with the Supreme Court.
ISSUE RAISED
- The issue raised before the Supreme Court is that, is it valid that the appellant was found guilty under Section 498A of the IPC, despite the accused being cleared of all charges under Section 306 of the IPC by the High Court?
CONTENTIONS OF APPELANT
- On behalf of the appellant, the learned counsel strongly stated that the deceased’s injuries were so serious (96 percent burns) that they would have prevented her from communicating at all. Therefore, it is not appropriate to give credence to the testimony of the prosecution witnesses (PW-1 through PW-3).
- There was also a claim that the deceased’s arguments—especially with her spouse about his return to Saudi Arabia—and other family members contributed to her death. According to the defence, these domestic disputes do not meet the criteria for Section 498A IPC harassment.
- Alternatively, in the event that the court upholds the conviction, a more forgiving attitude toward the appellant’s age ought to be taken. A sentence reduction was requested, and she was described as an older woman who was almost 80 years old.
CONTENTIONS OF RESPONDENT
- The respondent, represented by the state did not show up or participated in the arguments.
JUDGEMENT
- The Supreme Court found that the trial and high courts had demonstrated and established that the deceased had become a victim of torture and cruelty at the hands of the appellant (mother-in-law) with reference to jewels. In this instance, the appeal against the excessive court order had been dismissed. The Supreme Court further declared that the subordinate courts’ judgments should be respected since they correctly found the accused guilty of crimes covered by section 498A of the IPC.
- Mentioning in the second appeal that the defendant is a woman who is eighty years old and that the penalty should be light. The accused grew close to sixty-five years old during the trial court procedures, according to the Supreme Court, and the trial court punished her with a year in prison and a fine. This occurred back in 2006, but as the accused is now eighty years old, the Supreme Court reduced the sentence from 365 days to a few months in addition to the fine that the trial court had already imposed.
- The mother-in-law, the appellant, should have shown her daughter-in-law greater consideration because she was a lady, the court ruled. An offense becomes more serious when it is committed by a woman who treats another woman cruelly, such as the daughter-in-law. It turns into a more severe offense. The second lady, the daughter-in-law, would be left vulnerable if one lady, the mother-in-law in this case, did not defend the other lady. In this instance, the victim’s spouse was also residing overseas. The victim was spending her time by herself at her in-laws.
- Consequently, it was the appellant’s responsibility as the mother-in-law and her family to look after her daughter-in-law rather than tormenting, abusing, or cruelly treating her over jewellery or other matters.
ANALYSIS
As we analysed the most recent ruling by the Supreme Court took a more lenient stance in situations involving abuse by in-laws in Indian communities. This new method does not exhibit any of the patriarchy that has long pervaded our society. The 21st century is not the time for antiquated methods, as this recent case demonstrates. People are now aware of their rights and are well-equipped to fight against any violations of them.
“Women are women’s worst enemies,” is a significant issue brought up in the ruling, but we can’t lump everyone together. The phrase “being human is given, but keeping our humanity is a choice” is true, and no matter what the circumstances, one should remember this idea. “Bhagavad Gita calls on humanity to dedicate body, mind and soul too pure duty and not to become mental voluptuaries at the mercy of random desires and undisciplined impulses.”
Confidence is fostered by education. Hope is bred by confidence. Confucius said, “Peace begets hope.” I agree with this phrase and believe that education is crucial in fostering a fearless mindset that leads to the ability to stand up for your own rights, as demonstrated by the mother of the deceased in the aforementioned case who did so in defence of her daughter’s rights.
I sincerely appreciate the Supreme Court for rendering a decision that will stand as a standard in future cases involving abusive in-laws. Such judgment strengthens society and serves as a foundation for more significant changes in Indian society. A thousand miles, as we all know, start with one step. For a man, this is one modest step, but for mankind, it is a gigantic leap.
CONCLUSION
In this instance, the appellant’s conviction according to Section 498A of the IPC was upheld by the Supreme Court. The deceased person’s mother-in-law was the appellant. The court concluded that the appellant had treated the deceased harshly and tormented her regarding the jewellery. However, because of the appellant’s advanced age and the fact that the incident occurred in 2006, the Court reduced the sentence from one year to three months of rigorous imprisonment. The Court determined that no leniency was justified in this case, emphasizing the importance of protecting the weak. The appellant was given a four-week deadline to appear in order to finish her sentence reduction.
REFERENCES
- https://www.legalserviceindia.com/legal/article-7734-meera-v-s-state-by-inspector-of-police-thiruvotriyur-police-station-chennai.html
- https://www.livelaw.in/tags/meera-v-state-by-the-inspector-of-police-thiruvotriyur-police-station-chennai
- https://www.lawyersclubindia.com/judiciary/supreme-court-affirms-conviction-of-mother-in-law-in-harassment-case-under-section-498a-ipc-reduces-sentence-on-grounds-of-age-in-meera-vs-state-by-the-inspector-of-police-6743.asp
- https://indiankanoon.org/doc/171194008/
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