Criminal proceedings against in-laws cannot stand on general allegations lacking specific roles.

The complainant alleged that she married petitioner no. 1, Arvind Rai, and that her father spent ₹2 lakhs on the marriage; she further alleged a subsequent demand for ₹4 lakhs, assaults, and that she was driven from the matrimonial home.

The complaint was filed on 13 July 2016, and the S.D.J.M., Vaishali at Hajipur, took cognizance under Sections 498A/34 IPC and Section 4 of the Dowry Prohibition Act on 20 January 2017.

Petitioners nos. 2 and 3, the complainant’s father-in-law and mother-in-law, sought quashing of the cognizance order.

The husband’s case had been withdrawn, and he would continue to face the complaint case.

The petitioners argued that the allegations against the parents-in-law were general and omnibus, without specific acts, dates, or events.

Whether the cognizance order should be quashed as against petitioners nos. 2 and 3 where the complaint made no specific allegations of their individual conduct.

Whether the stated circumstances, including the discrepancies in the dates and the delay in filing the complaint, supported quashing the proceedings against those petitioners.

The Court considered Sections 498A and 34 of the Indian Penal Code and Section 4 of the Dowry Prohibition Act, under which cognizance had been taken.

Relying on Abhishek v. State of Madhya Pradesh, 2023 SCC OnLine SC 1083, the Court applied the principle that general and omnibus allegations against a husband’s relatives, without clear and specific allegations, may amount to an abuse of the process of law; the judgment’s discussion of that authority also refers to Kahkashan Kausar v. State of Bihar, Preeti Gupta v. State of Jharkhand, Neelu Chopra v. Bharti, and Mahmood Ali v. State of U.P.

The Court found that the allegations against petitioners nos. 2 and 3 were general and omnibus and disclosed no specific overt act, date, or event attributable to them; the principal thrust of the complaint was against the husband.

It also noted that the complaint gave dates the Court considered incorrect, and that the alleged date of being driven out preceded the stated marriage date.

The Court further noted the delay apparent on the complainant’s own dates.

Applying the principles in Abhishek concerning unsupported, general allegations against relatives in matrimonial disputes, the Court concluded that the proceedings could not continue against the parents-in-law.

The husband’s case was not quashed by this order and remained for him to contest.