General and omnibus allegations against in-laws warrant quashing of matrimonial-cruelty proceedings.

Opposite Party No. 2 alleged that, after her marriage to Shrikant Singh in 2018, her husband and his family members demanded a car and subjected her to physical and mental cruelty.

She alleged that, despite her father providing a vehicle, the assault and threats continued, and that she was driven out of her matrimonial home on 26 June 2020.

The petitioners—Ram Pravesh Singh, Prabha Devi, and Shashi Kant Singh—were respectively the father-in-law, mother-in-law, and brother-in-law of the informant.

The Chief Judicial Magistrate, Aurangabad, took cognizance against the petitioners under Section 498-A of the Indian Penal Code and Sections 3/4 of the Dowry Prohibition Act by order dated 7 February 2023.

The petitioners invoked the High Court’s inherent jurisdiction to quash the cognizance order.

Whether the criminal proceedings against the petitioners under Section 498-A IPC and Sections 3/4 of the Dowry Prohibition Act should be quashed where the allegations against the husband’s relatives are general, omnibus, and unsupported by specific overt acts?

Whether continuation of the proceedings against the petitioners amounted to an abuse of the process of court, particularly when the alleged incidents occurred in Madhya Pradesh and no specific continuing cause of action at Aurangabad, Bihar, was pleaded?

The Court considered the offences under Section 498-A IPC, concerning cruelty by the husband or his relatives, and Sections 3/4 of the Dowry Prohibition Act, concerning giving or taking dowry and demanding dowry.

It exercised the inherent jurisdiction under Section 482 CrPC to prevent abuse of the process of court and to secure the ends of justice.

Relying on Preeti Gupta v. State of Jharkhand, (2010) 7 SCC 667, and Geeta Mehrotra v. State of Uttar Pradesh, (2012) 10 SCC 741, the Court recognised the need for caution where relatives are implicated in matrimonial disputes on the basis of vague allegations.

It further applied Abhishek v. State of Madhya Pradesh, 2023 SCC OnLine SC 1083, including the principle drawn from Kahkashan Kausar v. State of Bihar, (2022) 6 SCC 599, that general and omnibus allegations against the husband’s family members, absent specific allegations, may constitute misuse of criminal process and justify quashing.

The Court also relied on Dara Laxmi Narayana v. State of Telangana, (2025) 3 SCC 735, which reiterates that matrimonial criminal proceedings against family members lacking specific allegations should be nipped in the bud.

The Court examined the FIR and found that the allegations against the petitioners were general, omnibus, and sweeping, while the allegations relating to the demand for a car and the matrimonial discord were substantially directed against the husband.

The agreement dated 23 June 2020, relied upon in the FIR, was between the informant and her husband and did not involve any of the petitioners, weakening the case against them.

The Court held that the petitioners had been implicated principally because of their relationship with the husband, without specific dates, acts, or circumstances attributing cruelty or dowry demand to each petitioner.

Applying the Supreme Court’s caution against prosecuting relatives on vague allegations in matrimonial disputes, the Court concluded that allowing the prosecution to continue would amount to an abuse of the process of court.

It additionally noted that the alleged incidents took place in Madhya Pradesh and that the FIR did not plead any continuing impact of cruelty or specific cause of action at Aurangabad, Bihar.

It held that the allegations against the father-in-law, mother-in-law, and brother-in-law were insufficiently specific and that continuation of the prosecution against them would constitute an abuse of process.

Accordingly, the cognizance order dated 7 February 2023 in Madanpur P.S. Case No. 40 of 2022 was quashed insofar as it related to the three petitioners, and the application under Section 482 CrPC was allowed.