Omnibus allegations against distant relatives in matrimonial disputes without specific overt acts warrant quashing under Section 482.

The applicants (parents-in-law and two sisters-in-law) sought to quash FIR No. 11191008201178 dated 25.10.2020 and the resulting Criminal Case No. 3443 of 2021

The de facto complainant (Respondent No. 2) alleged that between 2013 and 2020, the applicants subjected her to physical and mental torture, verbal abuse, and beatings due to "meager dowry"

The applicant sisters-in-law (Nanands) had been married and residing in separate matrimonial homes since 2007 and 2013, respectively

Evidence showed the parents-in-law had issued a public notice in March 2020 disowning their son (the complainant’s husband) due to his conduct

1. Whether the FIR and subsequent criminal proceedings against the relatives of the husband should be quashed under Section 482 of the CrPC to prevent the abuse of the process of law

2. Whether the allegations in the FIR, being vague and omnibus without specific overt acts, prima facie constitute the alleged offences under Sections 498A, 323, 294(b), and 114 of the IPC and the Dowry Prohibition Act

Section 482 of the Criminal Procedure Code, 1973, concerning the High Court's inherent power to prevent abuse of the process of law

Landmark categories for quashing established in State of Haryana v. Bhajan Lal (1992), particularly regarding cases motivated by malice or lacking a prima facie offence

Principles from Preeti Gupta v. State of Jharkhand (2010), Arnesh Kumar v. State of Bihar (2014), and Kahkashan Kausar @ Sonam v. State of Bihar (2022), which warn against the increasing tendency to rope in distant relatives in matrimonial disputes through vague, "omnibus" allegations

The court found that the allegations against the applicants were vague, omnibus, and failed to attribute specific roles or instances of involvement

The court noted that the sisters-in-law lived separately in their own matrimonial homes for years, and the parents-in-law had historically disowned the husband, suggesting they were unlikely to be involved in day-to-day harassment

Relying on K. Subba Rao v. State of Telangana, the court emphasized that scattered incidents without immediate proximity do not constitute cruelty under Section 498A

The court concluded the FIR was a "pressure tactic" and "manifestly frivolous," instituted with an ulterior motive for wreaking vengeance following a matrimonial fallout

The FIR (C.R. No. 11191008201178) and Criminal Case No. 3443 of 2021 were quashed and set aside specifically regarding the four applicants (parents-in-law and sisters-in-law). Rule made absolute.