Inherent Powers Under Section 528 BNSS Cannot Be Invoked to Adjudicate Disputed Factual Defence Pleas

The petitioners (in-laws of the complainant) sought to quash G.R. Case No. 280 of 2024 arising from an FIR alleging offences under Sections 498-A, 294, 323, 506, 406, and 34 of the IPC, and Section 4 of the Dowry Prohibition Act.

The complainant (Opposite Party No. 2) married Ratnala Srinivas Rao in September 2023.

She alleged that shortly after the marriage, the petitioners demanded additional dowry (a motorcycle, cash, and property) and subjected her to physical assault, including a burn injury caused by a hot iron tawa.

Following an investigation, the police filed a charge-sheet, and the SDJM, Rayagada, took cognizance of the offences on July 19, 2024.

The petitioners contended the allegations were "omnibus and general," designed to harass the in-laws during a matrimonial discord.

1. Whether the allegations in the FIR and charge-sheet are vague and omnibus in nature, warranting quashing of the proceedings against the in-laws.

2. Whether the Magistrate took cognizance in a mechanical manner without application of judicial mind to the specific roles of the petitioners.

3. Whether the High Court should exercise its inherent power under Section 528 of the BNSS (formerly Section 482 CrPC) to prevent an abuse of the process of law.

The Court primarily applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the inherent powers of the High Court.

It relied on the landmark precedent State of Haryana v. Bhajan Lal, which established that inherent powers must be exercised sparingly and only when the uncontroverted allegations fail to disclose a cognizable offence.

The court also applied the principles governing Section 498-A of the IPC (cruelty by husband or relatives) and Section 4 of the Dowry Prohibition Act, emphasizing that at the stage of cognizance, the court is only required to find a prima facie case rather than proof beyond reasonable doubt.

The Court reasoned that the inherent jurisdiction under Section 528 BNSS is limited and should not involve a "roving enquiry" or a "mini-trial" of disputed facts.

Upon examining the 161 Cr.P.C. statements and the FIR, the Court found that the allegations were not merely "bald or omnibus assertions" but attributed specific participation to the petitioners regarding dowry demands and ill-treatment.

The Court rejected the defense plea that some petitioners lived separately, noting that residency elsewhere does not automatically exonerate an accused if active participation in harassment is alleged.

It further held that the SDJM's order was not mechanical, as it was based on the submitted charge-sheet and medical evidence relating to the complainant's injuries.

The petition for quashing was dismissed, the order of cognizance was upheld, and any prior interim stay was vacated; the Court directed that the proceeding in G.R. Case No. 280 of 2024 shall continue before the SDJM, Rayagada, in accordance with law.