The Consistency Doctrine in Matrimonial Offences: Supreme Court’s Clarification in Disha Kapoor v. State of Uttar Pradesh (2025)

1. Introduction

The Supreme Court of India, in Disha Kapoor v. State of Uttar Pradesh & Ors. (2025 INSC 649), once again traversed the delicate terrain of matrimonial litigation where criminal law, family law and societal expectations intersect. The petitioner (wife) challenged an order of the Allahabad High Court quashing criminal proceedings—initiated upon her Section 156(3) CrPC complaint and founded primarily on allegations under Section 498A IPC and the Dowry Prohibition Act—against her husband and his parents. The apex court, finding “many inconsistencies” and “contrary stands,” refused to interfere, thereby reaffirming the power and duty of courts to weed out “abuse of process” through Section 482 CrPC.

Although no new statutory provision was created, the judgment crystallises and reiterates what may now be labelled the “Consistency Doctrine”: in matrimonial offence complaints, material inconsistencies between the written complaint, sworn statements and other contemporaneous documents can, by themselves, justify quashing at the threshold.

2. Summary of the Judgment

• The petitioner lodged a multi-accused complaint alleging cruelty and dowry demands. The Magistrate summoned only the husband and his parents, citing Geeta Mehrotra.
• The husband’s Section 482 CrPC petition succeeded before the High Court, which relied on Preeti Gupta to hold the proceedings an abuse of process.
• On SLP, the Supreme Court examined the record, noted contradictions in dates, absence of medical proof of alleged fracture, and admissions in family-court affidavits showing cordiality during the same period.
• Holding that criminal law cannot be allowed to become a weapon in matrimonial disputes, the Court dismissed the SLP and endorsed the High Court’s quashing.

3. In-Depth Analysis

3.1 Precedents Cited and Their Influence

1. Geeta Mehrotra & Anr. v. State of U.P. (2012) 10 SCC 741
   • Established that distant relatives should not be mechanically roped in absent specific, direct allegations.
   • The Magistrate used this ruling to limit summons only to husband and parents-in-law.
2. Preeti Gupta & Anr. v. State of Jharkhand (2010) 7 SCC 667
   • Strongly deprecated the trend of “over-implication” in matrimonial complaints.
   • Directed courts to be “doubly cautious” and invoked Section 482 CrPC whenever proceedings amount to harassment.
   • Formed the central plank of the High Court’s quashing and was approved by the Supreme Court here.

While not expressly cited in the judgment, earlier leading decisions—State of Haryana v. Bhajan Lal, Arnesh Kumar v. State of Bihar, and Manik Taneja v. State of Karnataka—form the doctrinal background to Section 482 jurisprudence. Disha Kapoor functions as a fact-specific extension that sharpens the role of Bhajan Lal categories (particularly Category 7: “No sufficient ground for proceeding”).

3.2 Legal Reasoning of the Court

1. Primacy of Internal Consistency – The Court juxtaposed the petitioner’s Section 200/202 statements, the Section 156(3) application, and her affidavit in family-court proceedings. Contradictions on (i) dates of alleged ouster, (ii) presence of injuries, and (iii) subsequent cordial interactions (e.g., Rs. 50,000 Cheque for ‘Karwa Chauth’) undercut reliability.
2. Absence of Prima Facie Evidence – Vague averments of “beating” without medical record or contemporaneous police complaint were considered insufficient to summon the husband’s extended family, let alone sustain criminal trial.
3. Section 482 CrPC as a Filter – Quoting Preeti Gupta, the Court reiterated that Section 482 is not merely discretionary; it is a judicial obligation where continuation of proceedings defeats the “ends of justice.”
4. Neutral Approach During Pending Matrimonial Appeal – The Court declined to delve into evidence led before the Family Court to avoid prejudice, limiting itself strictly to contradictions apparent on the criminal record.

3.3 Impact and Prospective Significance

• Elevation of the “Consistency Doctrine”: Future complaints of matrimonial cruelty will likely be scrutinised for alignment between pleadings, statements and independent evidence at the very first stage.
• Deterrence of Over-Implication: The judgment adds momentum to the movement against indiscriminate arraying of extended relatives, thereby safeguarding innocent parties and preventing clogging of criminal courts.
• Guidance for Magistrates: Trial courts gain authoritative backing to reject or prune complaints where contradictions or generalised allegations are manifest.
• Balanced Feminist Jurisprudence: While protecting women from genuine cruelty remains paramount, the Court signals that weaponisation of Section 498A will be met with robust judicial resistance.

4. Complex Concepts Simplified

Section 156(3) CrPC

An enabling provision allowing a Magistrate to direct police to register an FIR and investigate when a cognisable offence is disclosed.

Section 200 / 202 CrPC Examination

Stages where the Magistrate records the complainant’s statement (Section 200) and, if needed, postpones process for further inquiry or witness statements (Section 202) before issuing summons.

Section 482 CrPC

Inherent power of the High Court to (i) prevent abuse of the court process and (ii) secure the ends of justice. Used to quash FIRs or complaints lacking prima facie merit.

Section 498A IPC

Penal provision against cruelty by husband or relatives towards a married woman. Broadly construed to include mental and physical cruelty linked or unlinked to dowry.

Dowry Prohibition Act, 1961 (Sections 3/4)

Criminalises giving, taking or demanding dowry and related harassment.

5. Conclusion

Disha Kapoor v. State of Uttar Pradesh reinforces the judiciary’s gate-keeping role in matrimonial prosecutions. The Court’s refusal to interfere with the High Court’s quashing underscores that:

• Material inconsistencies in a complainant’s narrative are fatal at the threshold.
• Section 482 CrPC is an indispensable safeguard—not an exceptional indulgence—against the abuse of criminal law in domestic disputes.
• The burden is on complainants to corroborate allegations of cruelty or dowry demand with coherent, contemporaneous evidence.

Going forward, the “Consistency Doctrine” will likely permeate decisions across jurisdictions, compelling litigants and counsel to draft and pursue complaints with heightened factual precision, and enabling courts to strike a finer balance between redressing genuine victimisation and protecting the innocent from vexatious litigation.