Omnibus allegations without specific overt acts cannot sustain cruelty prosecutions against relatives.

The complainant alleged that, after her marriage in 2015, she was subjected to abuse and cruelty by her husband and his family.

Among other allegations, she said that Mohammad Mahfuzul Haque and his wife pressured her husband to leave his job and join their company, and pressured her to provide her brother’s PAN card for the company’s Bengaluru operations.

She also alleged that her mother-in-law pushed her while she was 24 weeks pregnant; the child was stillborn the next day.

A complaint dated 23 November 2017 led to Crime No. 410/2017 and a charge sheet.

The petitioners, described in the judgment as accused Nos. 3 to 6, sought quashing under Section 482 Cr.P.C. (and, in the later petitions, Section 528 BNSS), contending that the allegations did not disclose specific overt acts by them.

The complainant and State opposed quashing, relying on the complaint and witness statements.

1. Whether the complaint and accompanying material disclosed specific allegations sufficient to proceed against the petitioners for the alleged offences

2. Whether continuing the proceedings against the petitioners would amount to an abuse of process warranting the High Court’s inherent jurisdiction

The Court considered the High Court’s inherent powers under Section 482 Cr.P.C. to prevent abuse of process and secure the ends of justice; it also referred to Section 528 BNSS in describing the later petitions.

The Court stated that an investigation is warranted where a complaint discloses an offence, but that the High Court need not conduct a mini-trial when deciding a quashing petition.

It considered the principles discussed in Renuka v. State of Karnataka and another, Muskan v. Ishaan Khan (Sataniya) and others (SLP (Criminal) No. 1531/2025), and Mahendrabhai Chandr… Patel and another v. State of Gujarat and others; the judgment provides no further citation details.

The Court found that the allegations against the petitioners were limited to pressuring the complainant’s husband to leave his job and join their company, and pressuring her to provide her brother’s PAN card.

It found no specific allegation that the petitioners participated in the alleged assault by the mother-in-law or were present when it occurred; the complaint stated that the husband was also absent at that time.

Although the complainant relied on witness statements and the hospital record, the Court concluded that the material did not establish specific accusations against these petitioners.

It therefore treated their implication as an instance of roping in family members in a matrimonial dispute and held that continuing proceedings against them would constitute an abuse of process.

Although the connected 2025 petitions sought quashing of proceedings in S.C. No. 1536/2023 and C.C. No. 21243/2023, the operative clauses do not expressly identify those proceedings.