A husband’s relatives cannot face prosecution for dowry cruelty on vague, omnibus allegations alone.

The complainant’s 2006 marriage to Mobin was followed, according to her allegations, by demands for ₹2 lakh and an Alto car and harassment when those demands were not met.

She alleged that on 27 March 2014, at her parental home, Mobin demanded the money and car, assaulted her, and threatened to desert her; the FIR was registered on 3 April 2014 after she learned that Mobin had contracted a second marriage.

Although the FIR initially invoked Sections 498-A and 307 IPC and Sections 3/4 of the Dowry Prohibition Act, the charge-sheet was filed under Section 498-A IPC and Sections 3/4 of the Act.

The husband’s relatives challenged the resulting criminal proceedings under Section 482 CrPC, contending that the allegations against them were general and omnibus. The mother-in-law and father-in-law died during the proceedings.

1. Whether the general allegations of dowry demand and harassment, without specific acts attributed to the husband’s relatives, were sufficient to sustain prosecution against them under Section 498-A IPC and Sections 3/4 of the Dowry Prohibition Act.

2. Whether continuation of the criminal proceedings against the applicants would amount to an abuse of the process of the court warranting relief under Section 482 CrPC.

Section 482 CrPC empowers the High Court to prevent abuse of the process of a court and secure the ends of justice. Section 498-A IPC criminalises specified forms of cruelty by a husband or his relative, including harassment to coerce a woman or a person related to her to meet an unlawful demand; Sections 3 and 4 of the Dowry Prohibition Act address giving or taking dowry and demanding dowry, respectively.

Applying Dara Lakshmi Narayana v. State of Telangana, (2025) 3 SCC 735; Rajesh Chaddha v. State of U.P., 2025 SCC OnLine SC 1094; and Dr. Sushil Kumar Purbey v. State of Bihar, 2026 SCC OnLine SC 338, the Court reiterated that vague, sweeping allegations or merely naming a husband’s relatives, without particularised allegations indicating their involvement, cannot by themselves sustain prosecution; the High Court may quash such proceedings under Section 482 CrPC.

The complainant attributed the specific acts at the parental home—demanding dowry, assaulting her, and attempting to strangle her—to Mobin. As to the applicants, the allegations were only that they joined in the dowry demands and harassment; the complaint did not identify their individual acts or explain each applicant’s role in the alleged offences.

The Court therefore considered the allegations against the relatives insufficiently particularised to justify continuing their prosecution, notwithstanding the prosecution against the husband. It concluded that requiring the applicants to face trial on those allegations would constitute an abuse of the court’s process.

It expressly left the proceedings against Mobin unaffected, directed the trial court to conclude that trial preferably within six months, and stated that its observations would not bind the trial court.