Matrimonial prosecution of in-laws cannot rest on vague allegations lacking specific instances of involvement.

Respondent No. 2 married accused No. 1 in 2007 in a love marriage and initially lived with the petitioners, his parents.

She alleged that accused No. 1 later had extramarital affairs and subjected her to physical and mental harassment, and that the petitioners supported him when she asked them to intervene.

Following her complaint, the police registered a case and filed a charge sheet against accused No. 1 and the petitioners under Sections 498A, 504, 506 read with Section 34 of the IPC and Section 4 of the Dowry Prohibition Act, 1961.

The petitioners, arrayed as accused Nos. 2 and 3, sought to quash the proceedings against them under Section 482 of the CrPC.

1. Whether the charge-sheet material disclosed specific allegations or a prima facie case against the petitioners for the charged offences

2. Whether continuing the criminal proceedings against the petitioners would amount to an abuse of the process of law warranting quashing under Section 482 of the CrPC

Section 482 of the CrPC empowers the High Court to quash criminal proceedings where their continuation would amount to an abuse of the process of the court.

In K. Subba Rao v. State of Telangana, 2024 INSC 960, the Supreme Court cautioned against prosecuting relatives in matrimonial disputes on omnibus allegations without specific instances of involvement.

In Dara Lakshmi Narayan v. State of Telangana, (2025) 3 SCC 735, the Supreme Court held that generalized accusations unsupported by concrete, particularized allegations cannot, by themselves, sustain prosecution of family members in matrimonial cases; courts must scrutinize such allegations to prevent misuse of criminal process.

The Court examined the complaint and charge-sheet material and found that the allegations against the petitioners were general, omnibus and hearsay: they were said to have supported their son rather than advise him, but no specific incident, date or overt act was attributed to them.

The witness statements did not substantiate the allegations.

Applying the Supreme Court’s caution against proceeding against relatives on vague allegations, the Court concluded that the material did not justify continuing the prosecution against these petitioners.

It allowed the petition and quashed the proceedings in C.C. No. 424/2022, arising out of Crime No. 39/2021, against the petitioners for the offences under Sections 498A, 504, 506 read with Section 34 of the IPC and Section 4 of the Dowry Prohibition Act, 1961.