Karnataka HC Quashes Dowry-Harassment Case Against Separately Living Sisters-In-Law Over Omnibus Allegations

Respondent No. 2 alleged that, after her marriage to accused No. 1, she was harassed by him, his parents and the petitioners—his sisters-in-law—for additional dowry.

She also alleged that the petitioners visited her parental home on 26 July 2022 and assaulted her and her parents. Police registered Crime No. 24/2023 and, after investigation, filed a charge sheet against the petitioners and other accused for offences under Sections 498A, 323 and 506 read with Section 34 of the IPC, and Sections 3 and 4 of the Dowry Prohibition Act, 1961. The petitioners sought to quash the proceedings under Section 482 of the Cr.P.C., arguing that they lived separately and that the allegations against them were general and unsupported by specific overt acts

Section 482 of the Cr.P.C. empowers the High Court to quash criminal proceedings to prevent abuse of the process of the court. The Court considered Sections 498A, 323 and 506 read with Section 34 of the IPC, and Sections 3 and 4 of the Dowry Prohibition Act, 1961.

Relying on *K. Subba Rao v. State of Telangana*, 2024 INSC 960, and *Dara Lakshmi Narayan v. State of Telangana*, (2025) 3 SCC 735, the Court applied the principle that relatives should not be prosecuted in matrimonial disputes on the basis of mere name-checking or vague, omnibus allegations; specific allegations indicating their involvement are required

The Court noted that the petitioners were the complainant’s sisters-in-law and that they lived separately with their respective families. While the complaint contained specific allegations concerning accused Nos. 1 to 3, the charge-sheet material did not identify specific instances—such as their date, time, place or manner—of harassment by the petitioners.

The allegations against them were therefore omnibus and, even if accepted at face value, did not make out a prima facie case. Applying the cited authorities, the Court concluded that prosecuting the petitioners on that material would constitute an abuse of process

It quashed the proceedings against the petitioners, accused Nos. 4 and 5, in C.C. No. 10418/2023 arising out of Crime No. 24/2023, for the offences under Sections 498A, 323 and 506 read with Section 34 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act, 1961