General and omnibus allegations against in-laws, coupled with compromise, justify quashing matrimonial prosecution.

Tulsi Devi alleged that, after her marriage with Shashi Kumar on 12 May 2013, her in-laws demanded dowry of ₹1,00,000, which was allegedly paid by her father.

A further demand of ₹50,000 was allegedly made, and upon non-payment, the accused family members allegedly subjected her to torture and ousted her from the matrimonial home on 9 March 2016.

On the basis of the complaint, the learned S.D.J.M., Barh, Patna, took cognizance on 31 August 2016 of offences under Sections 498A and 420 of the Indian Penal Code against Asha Devi and Birendra Ram, the parents-in-law of the complainant.

The petitioners sought quashing of the cognizance order, contending that the allegations against them were general and omnibus, that they lived separately, and that they had no involvement in the complainant’s domestic affairs.

During the proceedings, the parties reported that the dispute had been compromised, and the complainant did not dispute the compromise.

Whether the cognizance order dated 31 August 2016 for offences under Sections 498A and 420 IPC against the petitioners was liable to be quashed where the allegations against them were general and omnibus.

Whether the criminal proceedings could be quashed in view of the compromise between the parties, particularly when the petitioners were in-laws and the allegations lacked specific attribution of acts.

The Court considered the offences alleged under Sections 498A and 420 of the Indian Penal Code.

It applied the principle governing quashing of criminal proceedings where relatives of the husband are implicated through general and omnibus allegations, particularly when the dispute has been compromised and continuation of the prosecution would serve no useful purpose.

The Court relied on Abhishek v. State of Madhya Pradesh, reported in 2023 SCC OnLine SC 1083, for the relevant principles concerning quashing of proceedings against in-laws in such circumstances.

The Court exercised its jurisdiction to set aside the cognizance order and consequential proceedings.

The Court noted that the petitioners were the complainant’s in-laws and that the allegations of dowry demand and cruelty were general and omnibus, without specific particulars demonstrating their individual involvement in the alleged acts.

The petitioners also asserted that they lived separately and were not connected with the day-to-day domestic affairs of the complainant and her husband.

Since the parties had subsequently compromised the dispute and the complainant did not contest that compromise, the Court found the case appropriate for applying the principles in Abhishek and for terminating the proceedings against the petitioners.

The cognizance order and all consequential proceedings against both petitioners were accordingly set aside and quashed.

The criminal miscellaneous petition was allowed, and the judgment was directed to be transmitted to the trial court along with the record, if any.