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Orissa High Court: IPC 498A Case Cannot Be Quashed Due to Invalid Marriage

Orissa High Court: IPC 498A Case Cannot Be Quashed for Invalid Marriage

The Orissa High Court has ruled that a case under Section 498A of the Indian Penal Code (IPC) cannot be dismissed just because the marriage is not legally valid. The court emphasized that allowing such a defense would be unfair to women who enter into relationships believing them to be valid marriages.

Case Background

A single-judge bench led by Justice G Satapathy rejected a petition from a man seeking to quash an FIR filed against him under IPC 498A. The woman who filed the case claimed to be his wife and alleged that:

  • She lived with him in his village for over 80 days.
  • He mentally and physically harassed her.
  • His mother denied her food, forcing her to starve.
  • He pressured her to bring ₹50,000 from her father.

A Family Court had previously ruled that their marriage was invalid and dismissed her plea under Section 125 of the CrPC (which provides maintenance to wives). However, the High Court found that the allegations in the FIR were enough to constitute an offence under IPC 498A.

Key Observations by the Court

Justice Satapathy ruled that:

  • A man cannot escape liability under IPC 498A by claiming the marriage was not valid.
  • Allowing such a plea would have a negative impact on women who enter into relationships in good faith.
  • The court cannot conduct an in-depth scrutiny of case materials under CrPC Section 482, which allows High Courts to prevent misuse of legal processes.

Final Verdict

On November 29, the High Court refused to quash the FIR, stating that the legal process must continue.

Impact of the Judgment

This ruling reinforces that women in relationships resembling marriage are still protected under IPC 498A, ensuring they cannot be abandoned or harassed without legal consequences.

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