Criminal prosecution of relatives requires specific allegations of active involvement.

Respondent No. 2 alleged that, after her 2011 marriage to petitioner No. 1, he began physically and mentally harassing her from 2019, assaulted her after she questioned his alleged extramarital relationship, and left the matrimonial home in 2022. She also alleged that petitioner No. 2, her mother-in-law, visited the home and encouraged petitioner No. 1 to harass her

Following her complaint dated 29 July 2023, police registered a case and filed a charge sheet against both petitioners under Sections 498A, 323 and 109 IPC and Sections 3 and 4 of the Dowry Prohibition Act; the Magistrate took cognizance

The petitioners sought quashing under Section 482 CrPC.

Whether the charge-sheet material disclosed a prima facie case against petitioner No. 1 warranting continuation of the criminal proceedings

Whether proceedings against petitioner No. 2 should be quashed where she did not reside with the couple and the allegations against her were omnibus and unsupported by specific material

Section 482 CrPC empowers the High Court to prevent abuse of the process of the court.

The alleged offences arose under Sections 498A, 323 and 109 IPC and Sections 3 and 4 of the Dowry Prohibition Act

Relying on K. Subba Rao v. State of Telangana, 2024 INSC 960, and Dara Lakshmi Narayan v. State of Telangana, (2025) 3 SCC 735, the Court stated that relatives should not be prosecuted merely because they are named in a matrimonial complaint; specific allegations of their active involvement are required, and generalized accusations unsupported by concrete material may justify quashing to prevent abuse of process

The charge-sheet materials, including statements of witnesses CWs. 2 and 3, corroborated allegations that petitioner No. 1 harassed the complainant; the Court held that these matters required testing at trial and disclosed a prima facie case

By contrast, petitioner No. 2 had not lived with the couple, and the material alleged only that she visited and encouraged harassment, without identifying specific incidents or providing supporting material. Applying the principles in K. Subba Rao and Dara Lakshmi Narayan, the Court concluded that continuing the prosecution against her would amount to an abuse of process

The petition was dismissed in respect of petitioner No. 1/accused No. 1, and proceedings against him were permitted to continue