Facts
The appellant challenged the Karnataka High Court's refusal to quash criminal proceedings under S.498A IPC. The principal dispute was whether the parties were legally married or merely in a live-in relationship. The appellant contended that S.498A IPC applies only to a legally valid marriage, whereas the complainant asserted that the relationship possessed all the attributes of marriage and therefore attracted the provision.
Issues Framed
(a) Whether a man in a relationship in the nature of marriage can be prosecuted under S.498A IPC.
(b) Whether criminal proceedings against the appellant were liable to be quashed.
Court’s Reasoning
(a) The Court held that although penal statutes ordinarily require strict construction, such interpretation cannot defeat the socially beneficial object of S.498A IPC. The provision was enacted to combat cruelty against women, and a purely literal interpretation would permit perpetrators to evade liability merely because the relationship lacked legal validity. The Court relied upon Reema Aggarwal v. Anupam and Rajinder Singh v. State of Punjab while preferring a purposive interpretation.
(b) The Court distinguished ordinary live-in relationships from relationships in the nature of marriage. Only those relationships satisfying the judicial tests evolved in D. Velusamy and Indra Sarma, and additionally demonstrating an intention to marry, would receive protection under S.498A IPC. The initial burden to establish these foundational facts rests on the complainant.
(c) Recognising the misuse of S.498A IPC, the Court directed that the safeguards in Arnesh Kumar would equally apply to such prosecutions and clarified that its interpretation is confined to S.498A IPC alone.
Held
The appeals were disposed of. The Supreme Court declined to quash the criminal proceedings, leaving the Trial Court to proceed in accordance with law, while clarifying that its observations on facts were confined to the quashing stage.
Ratio
Section 498A is held to be applicable to “live-in relationships” that qualify as “relationships in the nature of marriage” with the intent to marry being established as an intrinsic part thereof..
Relevant Para
Para 20
“It is held, therefore, that a woman in a “relationship in the nature of marriage” shall be protected under Section 498A, giving the word “husband” a purposive interpretation, keeping in view the reformative, corrective and socially beneficial intent of the Section.”
Case Details
Citation: 2026 INSC 784
Decided on: 03 August 2026
Case Title: Dr. Lokesh B.H. & Ors. v. State of Karnataka & Anr.
Court: Supreme Court of India
Bench: Sanjay Karol, J.; Nongmeikapam Kotiswar Singh, J.