Distant relatives cannot be prosecuted on omnibus matrimonial allegations without specific instances of involvement.

Respondent No. 2 alleged that, after her marriage to petitioner No. 1 on 29 November 2023, petitioners Nos. 1–3 physically and mentally harassed her for additional dowry, while petitioners Nos. 4–6 instigated that conduct.

The police registered Crime No. 46/2024 for offences under Sections 498A, 417, 504, 323, 506(2), 114 read with Section 34 IPC, Sections 3 and 4 of the Dowry Prohibition Act, and Section 3 of the Karnataka Prevention and Eradication of Inhuman Evil Practice and Black Magic Act, 2017.

The accused sought quashing under Section 482 CrPC; the High Court considered the petitioners’ distinct roles and the allegations in the complaint.

1. Whether the FIR and proceedings should be quashed against petitioners Nos. 4–6 because the complaint contained no specific allegations of their involvement.

2. Whether the FIR and proceedings should also be quashed against petitioners Nos. 1–3, against whom the complaint alleged dowry-related physical and mental harassment.

The petition invoked Section 482 CrPC (also described in the petition as filed under Section 528 BNSS), under which the High Court may prevent abuse of the process of court.

The Court applied the principle that, in matrimonial offences, relatives should not be prosecuted on omnibus allegations alone; specific instances of involvement must be disclosed, and courts should scrutinize allegations carefully to prevent abuse of criminal process.

It relied on K. Subba Rao v. State of Telangana, 2024 INSC 960, concerning caution in proceeding against distant relatives, and Dara Lakshmi Narayan v. State of Telangana, (2025) 3 SCC 735, on the need for specific allegations against family members in matrimonial disputes.

The complaint alleged that petitioners Nos. 1–3 harassed the complainant for additional dowry, which the Court considered sufficient at the FIR stage to disclose a prima facie case against them.

By contrast, the allegations against petitioners Nos. 4–6 were general and lacked particulars identifying any specific act, date, time, or manner of involvement.

Petitioners Nos. 5 and 6 lived separately at Birur, and no specific conduct was attributed to petitioner No. 4.

Applying the principles against prosecution based solely on omnibus allegations, the Court found that continuing the proceedings against petitioners Nos. 4–6 would amount to abuse of process, while the allegations against petitioners Nos. 1–3 required the proceedings to continue.

The petition was dismissed in respect of petitioners Nos. 1–3, and proceedings against them were permitted to continue.