Distant relatives cannot face matrimonial-cruelty prosecution on omnibus allegations absent specific instances of involvement.

Respondent No. 2 alleged that, after her marriage to petitioner No. 1, petitioners Nos. 1 and 2 harassed and assaulted her over an alleged unpaid dowry amount of ₹2,00,000; the complaint also alleged that petitioners Nos. 2 to 4 took her gold ornaments and attempted to poison her.

Police registered a case and filed a charge sheet against all four petitioners under Sections 498A, 323, 504, 506, 114 read with Section 34 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act, 1961. The Magistrate took cognizance, and the petitioners sought to quash the proceedings under Section 482 CrPC.

Petitioners Nos. 3 and 4 were the complainant’s sister-in-law and the sister-in-law’s husband, and were residing separately.

1. Whether the charge-sheet materials disclosed a prima facie case warranting continuation of proceedings against petitioners Nos. 1 and 2.

2. Whether the proceedings against petitioners Nos. 3 and 4 should be quashed where the allegations against them were general and lacked specific particulars of their alleged involvement.

Section 482 CrPC empowers the High Court to quash criminal proceedings where their continuation would amount to an abuse of process. The offences alleged were under Sections 498A, 323, 504, 506, 114 read with Section 34 IPC and Sections 3 and 4 of the Dowry Prohibition Act, 1961.

Relying on K. Subba Rao v. State of Telangana, 2024 INSC 960, the Court stated that relatives should not be implicated in matrimonial offences on omnibus allegations without specific instances of involvement.

It also relied on Dara Lakshmi Narayan v. State of Telangana, (2025) 3 SCC 735, for the principle that generalised accusations, without specific allegations indicating active involvement, cannot by themselves sustain criminal prosecution and require careful scrutiny to prevent abuse of process.

The complaint and witness statements alleged that petitioners Nos. 1 and 2, who lived with the complainant, repeatedly harassed and assaulted her over the alleged balance dowry, and referred to a panchayat concerning the dispute. Those materials disclosed a prima facie case that required assessment at trial, so the Court declined to quash proceedings against them.

In contrast, petitioners Nos. 3 and 4 lived separately, and the record contained no specific incident, date, time, or manner of their alleged commission of the offences; the allegations against them were omnibus. Applying the principles in K. Subba Rao and Dara Lakshmi Narayan, the Court found that continuing the prosecution against them would amount to an abuse of process.