Distant relatives cannot be prosecuted for matrimonial offences on vague, omnibus allegations alone.

Respondent No. 2 alleged that, after her marriage to petitioner No. 1, petitioners Nos. 1–3 subjected her to physical and mental harassment for additional dowry, and that petitioner No. 3 sought sexual favours with petitioner No. 2’s support. She also alleged that petitioner No. 4, her sister-in-law, urged petitioner No. 1 to marry again.

The police registered a case and filed a charge sheet against all four petitioners under Sections 498A, 354, 504 and 506 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act; the Magistrate took cognizance. The petitioners sought quashing under Section 482 CrPC, alleging fabrication and omnibus accusations. There was no representation for the petitioners on the second call before the High Court.

1. Whether the allegations and charge-sheet material warranted quashing the proceedings against petitioners Nos. 1–3.

2. Whether the proceedings against petitioner No. 4, a relative of the husband, should be quashed in the absence of specific allegations of her involvement.

Section 482 CrPC empowers the High Court to quash criminal proceedings where their continuation would constitute an abuse of process. In matrimonial prosecutions, relatives should not be prosecuted merely on the basis of omnibus allegations; courts must look for specific allegations or instances indicating the individual’s involvement.

The Court relied on K. Subba Rao v. State of Telangana, 2024 INSC 960, for caution against proceeding against distant relatives on general allegations, and Dara Lakshmi Narayan v. State of Telangana, (2025) 3 SCC 735, for the principle that vague, generalised accusations unsupported by particulars should not form the basis of prosecution of family members.

The Court found that the complaint alleged specific dowry-related harassment by petitioners Nos. 1–3 and that statements from the complainant’s family members and other witnesses disclosed their alleged involvement. Those allegations presented a prima facie case requiring examination at trial, so quashing their proceedings was not justified.

By contrast, petitioner No. 4 lived separately and no specific allegation of criminal conduct was made against her. Applying the caution expressed in the cited Supreme Court decisions, the Court held that continuing the prosecution against her would amount to an abuse of process.

The Court held that quashing the proceedings against petitioners Nos. 1–3 was not justified, but that continuing the prosecution against petitioner No. 4 would amount to an abuse of process.