Omnibus allegations without specific roles cannot sustain Section 498A prosecution against a husband’s relatives.

Opposite Party No. 2 alleged that, after her marriage to Md. Wasi Raza on 26 April 2003, she was subjected to physical and mental cruelty for failure to meet a further dowry demand of ₹2,00,000.

Her complaint was referred to the police, resulting in Nawada Mahila P.S. Case No. 18 of 2013; after investigation, a charge-sheet was filed and the Magistrate took cognizance under Sections 498-A read with 34 IPC on 4 December 2015.

The petitioners—relatives of the husband, including his brothers and sisters-in-law—sought quashing under Section 482 CrPC, contending that the allegations against them were general and omnibus.

1. Whether the allegations, taken at face value, disclosed the ingredients of an offence under Section 498-A IPC against each petitioner.

2. Whether the cognizance order and ensuing proceedings against the petitioners should be quashed under Section 482 CrPC because the allegations against them were general and omnibus.

Section 498-A IPC criminalises cruelty by a husband or his relative; “cruelty” includes wilful conduct likely to cause grave injury or danger to a woman’s health, and harassment intended to coerce her or a person related to her to meet an unlawful demand for property or valuable security.

Under Section 482 CrPC, the High Court may intervene to prevent abuse of process or secure the ends of justice, including where allegations taken at face value do not disclose the necessary ingredients of an offence; the power must be exercised sparingly and without conducting a meticulous evaluation of evidence.

The Court relied on Kahkashan Kausar @ Sonam v. State of Bihar, (2022) 6 SCC 599, for the principle that relatives should not be prosecuted on omnibus allegations without specific instances of involvement.

The judgment also cited Arti Mehta v. State of Madhya Pradesh, 2026 SCC OnLine SC 933, regarding careful scrutiny of allegations against each accused.

The Court examined the complaint and statements recorded during the inquiry and found that they did not specify the acts or conduct of any individual petitioner that could constitute cruelty under Section 498-A IPC.

Applying the principles in Kahkashan Kausar and Arti Mehta, it held that the petitioners’ relationship to the husband and the general allegations were insufficient to support prosecution without particulars showing their individual participation.

The Court therefore found that continuing the proceedings against them would amount to abuse of process.

It quashed the cognizance order dated 4 December 2015 and the entire criminal proceeding arising from Nawada Mahila P.S. Case No. 18 of 2013, insofar as it concerned the petitioners.