Omnibus allegations without specific overt acts cannot sustain prosecution of a mother-in-law in matrimonial cases.

Respondent No. 2 alleged that her husband, petitioner No. 1, and his family demanded dowry, including ₹10 lakh at the time of marriage, and that her husband later subjected her to physical and mental harassment, including in connection with an alleged extra-marital affair.

She also alleged that petitioner No. 1’s mother, petitioner No. 2, supported his conduct.

Following investigation, police filed a charge sheet against both petitioners for offences under Sections 498A, 504, 506 read with Section 34 of the IPC and Sections 3, 4 and 6 of the Dowry Prohibition Act.

The petitioners sought quashing under Section 482 CrPC; the High Court considered the allegations and witness statements in the complaint and charge-sheet materials.

1. Whether the charge-sheet proceedings against petitioner No. 2 should be quashed where the allegations against her were omnibus and did not identify a specific overt act.

2. Whether the proceedings against petitioner No. 1 should be quashed in light of the allegations of dowry-related and other harassment.

The Court considered its inherent jurisdiction under Section 482 CrPC to prevent abuse of the process of the court.

It applied the principle that, in matrimonial prosecutions, a relative of the husband should not be prosecuted merely because their name is included in the complaint; specific allegations indicating that person’s active involvement are required.

It relied on K. Subba Rao v. State of Telangana, 2024 INSC 960, and Dara Lakshmi Narayan v. State of Telangana, (2025) 3 SCC 735, which caution against criminal proceedings based on vague, generalised accusations against family members.

The complaint and witness statements contained allegations that petitioner No. 1 harassed respondent No. 2 over dowry and in connection with his alleged extra-marital affair. The Court therefore declined to quash the proceedings against him.

By contrast, the material against petitioner No. 2 consisted only of an omnibus allegation that she supported petitioner No. 1; it disclosed no specific act of harassment attributable to her.

Applying the cited principles, the Court held that continuing the prosecution against petitioner No. 2 would amount to an abuse of the process of the court.

The proceedings in C.C. No. 1631/2023 were quashed only against petitioner No. 2; they were to continue against petitioner No. 1.

The Court directed that its observations should not influence the trial court in deciding the case.