Dowry-harassment proceedings against relatives may be quashed where allegations are omnibus and parties have settled.

Manjula Devi alleged that, following her marriage to Manish Kant Dubey, her husband and his relatives—including the petitioners, her mother-in-law, father-in-law and married sister-in-law—harassed and assaulted her over demands for further dowry.

The Magistrate took cognizance against the petitioners under Sections 498A and 34 of the Indian Penal Code (IPC) and Sections 3 and 4 of the Dowry Prohibition Act.

The petitioners sought to quash that order, contending that the allegations against them were general and omnibus.

They also relied on the husband’s acquittal at trial and the informant’s evidence that the parties had settled and dissolved their marriage.

1. Whether the cognizance order and resulting proceedings against the petitioners should be quashed where the allegations against them were alleged to be general and omnibus.

2. Whether the parties’ settlement, dissolution of the marriage and the husband’s acquittal supported quashing the proceedings against the petitioners as an abuse of the process of the court.

The proceedings concerned offences under Sections 498A and 34 IPC and Sections 3 and 4 of the Dowry Prohibition Act.

The Court referred to Preeti Gupta v. State of Jharkhand, (2010) 7 SCC 667; Geeta Mehrotra v. State of U.P., (2012) 10 SCC 741; Rajesh Sharma v. State of U.P., (2018) 10 SCC 472; and Kahkashan Kausar v. State of Bihar, (2022) 6 SCC 599, cited for the principle that prosecution of a husband’s relatives on general and omnibus allegations, without specific accusations or overt acts, may amount to abuse of process.

The Court concluded that, in the circumstances before it, continuation of the proceedings would amount to an abuse of the process of the court.

The Court considered the petitioners’ contention that they were relatives of the informant’s husband and that the allegations against them lacked specific overt acts, alongside the cited Supreme Court decisions concerning omnibus allegations against relatives.

It also took account of the husband’s acquittal and the informant’s evidence in that trial that the parties had settled and their marriage had been dissolved.

On the combined facts, the Court found that continuing the proceedings against the petitioners would amount to an abuse of process.