Facts
The Petitioners (husband and in-laws) sought to quash Criminal Case No. 1379/2026 arising from FIR No. 91/2026, registered under Sections 85 and 3(5) of the Bhartiya Nyay Sanhita (BNS), 2023.
Source reference: p.2-3The Respondent No. 2 (wife) alleged that since their marriage in February 2023, she was subjected to harassment for a dowry of ₹8,00,000, a car, and jewelry.
Source reference: p.4She further alleged physical abuse and threats regarding private videos.
Source reference: p.4-5The Petitioners contended the allegations were bald, omnibus, and a "counter-blast" to matrimonial discord, noting that the wife frequently left the matrimonial home to live at her parental house or place of employment without just cause.
Source reference: p.6-8Mediation between the parties failed on 28.04.2026.
Source reference: p.2Issues
1. Whether the allegations in the FIR and charge-sheet, taken at face value, disclose a prima facie commission of a cognizable offence under Section 85 and 3(5) of the BNS.
Source reference: p.192. Whether the criminal proceedings constitute an abuse of the process of law warranting exercise of inherent powers under Section 528 of the Bhartiya Nagarik Suraksha Sanhita (BNSS)/Section 482 CrPC.
Source reference: p.20Law Applied
The Court applied Section 85 of the BNS (corresponding to Section 498A IPC) regarding cruelty and Section 3(5) of the BNS (corresponding to Section 34 IPC) regarding common intention.
Source reference: p.13-14, p.5It relied on the landmark principles in State of Haryana v. Bhajan Lal, which allow quashing where allegations are so absurd or inherently improbable that no prudent person could reach a conclusion of guilt, or where proceedings are maliciously instituted.
Source reference: p.9-12It further applied K. Subba Rao v. State of Telangana and Rashmi Chopra v. State of Uttar Pradesh, which established that relatives should not be roped into matrimonial disputes based on general, omnibus allegations lacking specific instances of involvement.
Source reference: p.17-19Reasoning
The Court examined the FIR and the statements accompanying the charge-sheet, finding them to be general, omnibus, and lacking specific particulars regarding dates or specific overt acts attributable to the petitioners.
Source reference: p.20It observed that the marriage lasted only three years, during which the complainant frequently moved between her parental home and place of work, suggesting matrimonial discord rather than systematic cruelty.
Source reference: p.7-8The Court noted that the allegations appeared to be "improvements and embellishments" inconsistent with earlier versions.
Source reference: p.20Applying the Bhajan Lal criteria, the Court reasoned that the prosecution was based on vague assertions and mala fide intent arising from matrimonial disagreement, falling under Categories 1, 3, and 7 of the established guidelines.
Source reference: p.20Consequently, allowing the trial to proceed would cause grave prejudice and amount to an instrument of harassment.
Source reference: p.20Holding
The Court answered the issues in the affirmative, holding that no prima facie case was made out and the proceedings were an abuse of process.
The Court quashed FIR No. 91/2026, the Final Report No. 88/2026, the cognizance order dated 09.03.2026, and all consequential proceedings in Criminal Case No. 1379/2026.
Source reference: p.21The Court further ordered the refund of ₹50,000 deposited by Petitioner No. 1 for mediation.
Source reference: p.21Original Court PDF
TEJ PRAKASH KHUNTE @ CHHOTUvsSTATE OF CHHATTISGARH
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