Supreme Court Modifies Sentence in Dowry Harassment Case: A Shift Towards Restorative Justice?

The Supreme Court of India recently delivered a landmark judgment in M. Venkateswaran vs. The State through inspector of police , addressing convictions under Section 498A of the Indian Penal Code (IPC) and Section 4 of the Dowry Prohibition Act (DP Act). While upholding the appellant’s conviction, the Court modified the sentence to the period already undergone (approximately three months) and imposed a ₹3 lakh compensation on the appellant. This ruling highlights the judiciary’s evolving approach toward restorative justice, balancing punishment with practical considerations in prolonged dowry-related cases.

What's the Matter?

In the case , the Supreme Court addressed a dowry harassment case where the appellant, M. Venkateswaran, was convicted under Section 498A IPC (cruelty) and Section 4 of the Dowry Prohibition Act (demanding dowry).

The case stemmed from his 2006 marriage to Sridevi (PW-4), which lasted only three days due to incessant demands for additional gold sovereigns (from 70 to 100) by Venkateswaran and his family. When the demands were unmet, Sridevi faced mental harassment, leading to a police complaint. The trial court sentenced him to three years imprisonment, which the High Court reduced to two years.

The Supreme Court, however, modified the sentence to the period already undergone (3 months) and imposed a compensation of ₹3 lakh on Venkateswaran, citing the 19-year delay in the case and the fact that both parties had moved on in life. This decision reflects a shift towards restorative justice, balancing accountability with practical considerations in long-pending case

Legal Analysis

Section 4 of the Dowry Prohibition Act (DP Act) If any person demands, directly or indirectly, from the parents or other relatives or guardian of a bride or bridegroom, as the case may be, any dowry, he shall be punishable with imprisonment for a term which shall not be less than six months, but which may extend to two years and with fine which may extend to ten thousand rupees:Provided that the court may, for adequate and special reasons to be mentioned in the judgment, impose a sentence of imprisonment for a term of less than six months.

Section 498A.   Husband or relative of husband of a woman subjecting her to cruelty.Previous    Next

1[Whoever, being the husband or the relative of the husband of a woman, subjects such woman to cruelty shall be punished with imprisonment for a term which may extend to three years and shall also be liable to fine.

Explanation.—For the purposes of this section, "cruelty means"—

(a) anywilful conduct which is of such a nature as is likely to drive the woman to commit suicide or to cause grave injury or danger to life, limb or health (whether mental or physical) of the woman; or

(b) harassment of the woman where such harassment is with a view to coercing her or any person related to her to meet any unlawful demand for any property or valuable security or is on account of failure by her or any person related to her to meet such demand.]

The case saw multiple stages of judicial scrutiny.

In 2016, the Trial Court convicted the appellant under Sections 498A (cruelty) and 406 (criminal breach of trust) IPC, along with Section 4 of the DP Act, sentencing him to three years of imprisonment.

In 2017, the Sessions Court acquitted him under Section 406 IPC but upheld the remaining convictions.

The High Court, in 2022, further reduced the sentence under Section 498A IPC to two years while maintaining one year under the DP Act, both to run concurrently.

Finally, in 2025, the Supreme Court modified the sentence to time served and imposed ₹3 lakh in compensation.

The legal framework governing the case primarily rests on Section 498A IPC, which criminalizes cruelty by a husband or his relatives, including harassment for dowry, and Section 4 DP Act, which penalizes demanding dowry with imprisonment ranging from six months to two years and/or a fine. The prosecution successfully established that the appellant harassed his wife (PW-4) to coerce her family into increasing the gold sovereigns from 70 to 100, causing significant mental distress.

Key evidence included testimony from PW-4, who detailed incessant dowry demands, the appellant’s refusal to attend the wedding reception unless demands were met, and his prior undisclosed marriage. PW-7 (the complainant’s mother) corroborated these allegations, while PW-11 (a photographer) highlighted the appellant’s family’s non-cooperation during the marriage ceremonies, linked to unmet dowry expectations. The Court deemed this evidence overwhelming and upheld the conviction, reiterating that such harassment squarely falls within the ambit of Section 498A IPC and Section 4 DP Act.

The Supreme Court’s rationale for reducing the sentence rested on three key factors.

First, the prolonged litigation spanned 19 years (2006–2025), imposing substantial mental and financial strain on both parties.

Second, the complainant had remarried and settled abroad, while the appellant, an IT professional, expressed a willingness to contribute through community service.

Third, the Court embraced a restorative approach, citing Samaul Sk. vs. State of Jharkhand (2021), emphasizing that since both parties had moved on, justice would be better served through compensation rather than further incarceration.

Compensation played a crucial role in the sentence reduction. The Court invoked the proviso to Section 4 DP Act, allowing for sentences below six months for “special reasons.” The appellant’s willingness to pay ₹3 lakh as compensation and his potential for community service were deemed sufficient mitigating factors.

This decision invites critical analysis. While acknowledging the victim’s trauma, it raises concerns about whether reduced sentences might weaken the deterrent effect of anti-dowry laws. It also prompts debate on whether offenders in protracted cases might exploit delays to seek sentence reductions. Furthermore, questions arise regarding the adequacy of ₹3 lakh in compensating 19 years of harassment.

The M. Venkateswaran judgment reflects the judiciary’s evolving approach in balancing legal rigor with humanitarian considerations. By prioritizing compensation and closure over prolonged incarceration, the Court signals a shift toward restorative justice in cases where both parties have rebuilt their lives. However, caution must be exercised to ensure that such leniency does not undermine the stringent objectives of the Dowry Prohibition Act.

Final Order:

• Convictions under Section 498A IPC and Section 4 DP Act upheld.

• Sentence reduced to time served (three months).

• Appellant directed to pay ₹3 lakh compensation to PW-4 within four weeks.

• Non-compliance will result in dismissal of the appeal and surrender for the remaining sentence.

This case underscores the importance of timely justice and the judiciary’s adaptability in addressing the socio-legal complexities of dowry-related harassment. Legal practitioners must navigate these precedents carefully, balancing accountability with rehabilitation.