Strict construction of Section 498A IPC bars treating a husband's girl friend or concubine as a relative for cruelty liability.

Section 498A IPC is a penal provision that must be strictly construed, and the term "relative" bears its ordinary meaning of a person related by blood, marriage or adoption. A mere extra-marital relationship does not create that status, so a husband's girl friend or concubine cannot be treated as a "relative of husband". On the facts, the appellant had no role in the dowry demand or the alleged acts of cruelty, and no offence under Section 498A was made out against her.

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Issues: Whether a girl friend or concubine of the husband of a married woman can be treated as a "relative of husband" within the meaning of Section 498A of the Indian Penal Code.

Analysis: Section 498A is a penal provision and must be strictly construed. The term "relative" is not defined in the Indian Penal Code and must therefore bear its ordinary meaning, namely a person related by blood, marriage or adoption. A mere extra-marital relationship does not create the status of a relative. The Court also noted that the appellant had no role in the demand of dowry or in the direct acts of cruelty alleged against the husband. The expression "relative of husband" cannot be stretched to include a girl friend or concubine.

Conclusion: The appellant was not a relative of the husband of the first informant and no offence under Section 498A of the Indian Penal Code was made out against her.

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