General and omnibus allegations against husband's relatives in matrimonial disputes warrant quashment of criminal proceedings.

The marriage of respondent No. 2 (complainant) and Arun Sharma was solemnized on January 18, 2025.

The complainant alleged that shortly after marriage, her husband and in-laws, including the petitioner (younger brother-in-law), harassed her for additional dowry of Rs. 10,00,000 and a four-wheeler, eventually expelling her from the matrimonial home.

An FIR was registered under Sections 85, 296, 351(3), and 3(5) of the BNS and Section 4 of the Dowry Prohibition Act.

The petitioner, a 19-year-old student, sought quashment of the FIR, contending that the allegations against him were vague and omnibus, and that the husband and wife actually resided separately in Rewa shortly after the marriage.

1. Whether the allegations in the FIR disclose specific overt acts against the petitioner sufficient to constitute the alleged offences.

2. Whether the continuation of criminal proceedings against a relative of the husband based on general and omnibus allegations constitutes an abuse of the process of law.

The court primarily applied Section 482 of the Cr.P.C. regarding the inherent powers of the High Court to prevent abuse of legal processes.

It relied on *State of Haryana v. Bhajan Lal*, which permits quashing when allegations do not disclose an offence or are mala fide.

Furthermore, it applied principles from *Kahkashan Kausar @ Sonam v. State of Bihar*, *Preeti Gupta v. State of Jharkhand*, and *Geeta Mehrotra v. State of Uttar Pradesh*, which established that criminal proceedings against relatives in matrimonial disputes should be quashed if the allegations are sweeping, general, or exaggerated without specific roles attributed to each individual.

The Court observed that while the FIR contained serious allegations against the husband and parents-in-law, it lacked specific assertions regarding the petitioner's individual role.

No particular date, incident, or overt act of cruelty or dowry demand was attributed to the petitioner, who is a 19-year-old student.

The Court found the allegations to be "general and omnibus" in nature, fitting the "growing tendency" to implicate all relatives of the husband in matrimonial disputes as cautioned by the Supreme Court.

Applying the *Bhajan Lal* standard, the Court determined that since the FIR did not prima facie disclose a specific role for the petitioner, allowing the trial to proceed would subject him to unnecessary harassment and constitute an abuse of the judicial process.

The Court allowed the petition and quashed the FIR (Crime No. 249/2025) and all consequential proceedings specifically as they relate to the petitioner, Aman Sharma.

It clarified that proceedings shall continue against the remaining accused persons.