M. Venkateswaran vs. State represented by the Inspector of Police
Citation: 2025 INSC 106; Supreme Court of India
Bench: Justice K.V. Viswanathan, Justice S.V.N. Bhatti
Background
The case concerned M. Venkateswaran, who was convicted of dowry harassment and related offences following a marriage that lasted only three days. The complainant, Sridevi, alleged that she and her mother were subjected to harassment and unlawful demands for gold sovereigns by Venkateswaran and his family. The complaint was filed in August 2007, over a year after the marriage. The charges included Section 498A (cruelty by husband or relatives), Section 4 of the Dowry Prohibition Act (demanding dowry), as well as Sections 406, 420, and 506(2) of the IPC.
Judicial History
Trial Court: Convicted Venkateswaran under Section 498A IPC and Section 4 of the Dowry Prohibition Act, sentencing him to two years and one year of imprisonment respectively, to run concurrently. Charges against his father were abated due to his death.
High Court: Confirmed the conviction and sentences, with minor modifications.
Supreme Court: Venkateswaran appealed, challenging the conviction and the quantum of sentence.
Supreme Court’s Analysis
Evidence and Findings: The Supreme Court found sufficient evidence of harassment and unlawful dowry demands. Testimonies from the complainant and her mother, along with corroborative material, established that the accused subjected the complainant to cruelty with the intent to coerce her and her family into fulfilling dowry demands.
Legal Standards: The Court reaffirmed that Section 498A IPC (now Section 85 and 86 of the Bharatiya Nyaya Sanhita, 2023) penalizes cruelty by the husband or his relatives, and Section 4 of the Dowry Prohibition Act criminalizes direct or indirect dowry demands.
Sentence Modification: Acknowledging the prolonged litigation (nearly 19 years since the marriage) and the appellant’s offer to compensate the complainant, the Court reduced the sentence to the period already undergone (about three months in custody). The Court directed Venkateswaran to pay ₹3,00,000 as compensation to the complainant within four weeks, failing which the original sentence would revive.
Decision
Conviction under Section 498A IPC and Section 4 of the Dowry Prohibition Act upheld.
Sentence reduced to time already served, subject to payment of ₹3,00,000 compensation to the complainant.
If compensation is not paid within the stipulated time, the original custodial sentence will be enforced.
Significance
The judgment underscores the seriousness with which courts view dowry harassment, while also emphasizing restitution and closure in long-pending matrimonial disputes. The Supreme Court balanced punitive and rehabilitative justice, recognizing the need for compensation and the impact of protracted litigation on both parties.
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