The Jharkhand High Court has held that Section 498A IPC does not restrict cruelty to demands for 'dowry' alone. Any unlawful demand for property or valuable security made by a husband or his relatives against a wife constitutes cruelty under the provision. The court clarified that the second limb of Section 498A is broader than the Dowry Prohibition Act's definition and covers all coercive property demands, regardless of whether they qualify as dowry under that statute.

Section 498A IPC (now Section 85, BNS 2023) punishes a husband or his relatives for subjecting a wife to cruelty. The section has two limbs: (1) conduct likely to drive the woman to suicide or cause grave injury, and (2) harassment with a view to coercing her or her relatives to meet an unlawful demand for property or valuable security.

The Jharkhand High Court's ruling clarifies a critical interpretive question: the second limb is not confined to 'dowry' as defined under Section 2 of the Dowry Prohibition Act, 1961. That definition restricts dowry to property given or agreed to be given in connection with marriage. Section 498A, by contrast, uses the phrase 'unlawful demand for property or valuable security' — which is wider.

This means a demand made after marriage, or a demand for property unconnected to the marriage arrangement, can still attract Section 498A if it is coercive and causes harassment. The husband cannot escape liability by arguing that the demanded property does not fall within the technical dowry definition.

For CLAT PG, this ruling is a clean application question: examiners will present a fact pattern where the demanded property falls outside the Dowry Prohibition Act's definition and ask whether 498A is still attracted. The correct answer — yes — depends on understanding the two-limb structure of the section and the independence of the second limb from the DP Act.