Introduction:

In W.P.(C) 2139/2025, the Delhi High Court dismissed a writ petition filed by Ateesh Agarwal, who sought an inquiry into the financial status of his wife and her family after she alleged that they had paid ₹2 crores as dowry and spent additional crores on their wedding. A division bench of Chief Justice Devendra Kumar Upadhyaya and Justice Tushar Rao Gedela observed that the petition was primarily rooted in a matrimonial dispute and did not involve any violation of fundamental or statutory rights. The court further held that the petitioner had failed to indicate any provision under which such a complaint could be pursued before the Income Tax Department. It emphasized that the Income Tax Act does not provide a regulatory framework for adjudicating personal disputes arising from matrimonial discord. The petitioner had claimed that under Section 269ST of the Income Tax Act, cash transactions exceeding ₹2,00,000 are prohibited, and since his wife admitted to having given ₹2 crores as dowry, the Income Tax Department was duty-bound to investigate. The High Court, however, rejected this contention, ruling that disputed factual questions of this nature could not be examined under Article 226 of the Constitution.

Arguments of the Petitioner (Husband):

The petitioner, Ateesh Agarwal, contended that his wife and her family had publicly admitted to giving ₹2 crores in dowry, along with spending exorbitantly on the wedding. He submitted that as per Section 269ST of the Income Tax Act, cash transactions exceeding ₹2,00,000 are prohibited, and the authorities should have investigated whether the alleged funds were accounted for in the family’s Income Tax Returns (ITRs). The petitioner argued that there was a clear case of tax evasion and financial misconduct, as such large-scale unaccounted transactions could not have taken place without violating the law. He had approached the Income Tax Department, urging them to verify the financial records of his wife’s family, but his complaint was allegedly ignored. Aggrieved by this inaction, he filed a writ petition before the Delhi High Court, seeking directions to the tax authorities to take legal action for possible perjury and financial fraud. The petitioner maintained that his plea was in the public interest, as it involved the enforcement of income tax laws and the prevention of unaccounted financial transactions.

Arguments of the Respondents (Wife and Tax Authorities):

The respondents, including the Union of India and the wife’s family, opposed the petition, arguing that it was a misuse of legal provisions arising from a matrimonial dispute. The wife’s counsel contended that the husband had filed the plea solely to harass her and her family and that the allegations were being used as a retaliatory measure in response to the ongoing matrimonial conflict. They further asserted that the Income Tax Act does not provide a mechanism for private individuals to seek tax inquiries into personal disputes and that such matters must be handled strictly within the framework of taxation laws. The Income Tax Department also argued that the petitioner had not filed his complaint under any specific statutory scheme, nor had he demonstrated any violation of his fundamental or statutory rights. The authorities maintained that tax enforcement is based on independent investigations and cannot be triggered solely by disputes between private individuals. They also contended that the allegations made by the wife in her dowry case were subject to adjudication in criminal proceedings, and the tax authorities had no role in determining the truthfulness of such claims.

Court’s Judgment:

The Delhi High Court dismissed the petition, observing that the dispute was essentially matrimonial and did not warrant interference under Article 226 of the Constitution. The bench noted that the petitioner had failed to establish how his fundamental or statutory rights had been infringed. It held that the Income Tax Department was not obligated to respond to complaints that did not fall under any statutory scheme and that a private dispute over alleged dowry transactions could not form the basis for a tax inquiry. The court further observed that the petitioner was unable to specify any provision under which his complaint was maintainable. It also noted that the allegations of dowry payment were hotly contested and involved complex factual issues that could not be adjudicated in writ proceedings. The court reiterated that taxation laws cannot be used as a tool for settling personal scores, and directing the authorities to initiate an inquiry would set a dangerous precedent. In light of these findings, the High Court dismissed the petition, emphasizing that disputes of this nature should be resolved in appropriate legal forums rather than being brought before constitutional courts under the guise of tax law enforcement.