Factual Background
In the case of Aiyappa M.B. v. State of Karnataka petition contesting the actions taken for violations of Section 498-A read in conjunction with Section 34 of the Penal Code, 1860, and Section 4 of the Dowry Prohibition Act, 1961. The woman lived in her marital house for a short period of time after the couple’s December 2019 wedding because their marriage quickly became strained. In February 2020, the woman filed a criminal complaint under Section 498-A of the Penal Code of 1860 and Section 4 of the Dowry Prohibition Act of 1961 against her husband and in-laws. Under Section 12(1)(a) of the Hindu Marriage Act of 1955, she also filed a motion to dissolve her marriage on the grounds of cruelty. The wife claims that the husband never expressed any desire in having sexual relations. He liked to watch videos of the Brahmakumari sisters and was always disconnected. The wife also said that the husband had informed her that he was not interested in a sexual relationship since true love requires more than just a physical connection; it also requires a soul-to-soul connection. The marriage was eventually declared null and void in 2022, but the dowry demand and cruelty cases were still pending.
Argument Advance
The husband’s attorney asked for the proceedings to be halted, claiming that none of the charges met the criteria for an offence punishable under Section 498A. It was further contended that the wife merely lived in the marital home for 28 days and started legal proceedings by registering a complaint for an offense under Section 498A because the marriage had not yet been consummated. The parents of the husband, who had nothing to do with the matter, have been arbitrarily entangled in the web of criminality.
The wife’s attorney claimed that the husband’s parents had purposefully arranged for their son to marry her. The woman was forced to seek an annulment of the marriage because the husband never expressed any desire in having a sexual relationship with her. It was argued that the instant petition should be dismissed because the proceedings under Section 498-A and Section 12(1)(a) are still going on.
Analysis of Court order
The Karnataka High Court single judge bench of Justice M. Nagaprasanna ruled that the husband’s refusal to physically consummate the marriage due to his spiritual inclination would unquestionably amount to cruelty because the marriage was not consummated under Section 12(1)(a) of the Hindu Marriage Act, 1955, and not cruelty as defined by Section 498A of the Penal Code, 1860.
The wife’s petition to end their marriage because of his devotion to Brahmakumari spiritualism was reviewed by the court. Regarding the other accused parties, the father-in-law and mother-in-law, the Court noted that the wife alleges that they requested dowry at the time of marriage and that they instigated their son. The court also remarked that the spouse had embraced the annulment decree favourably. The Court found no evidence against the spouse and believed that if the contested processes were allowed to progress, they would turn into harassment, abuse of the legal system, and eventually, a miscarriage of justice. The court invalidated the criminal charges brought against the spouse and the wife’s in-laws.