Omnibus matrimonial allegations against in-laws may be quashed after spouses settle their disputes.

The complainant alleged that, after her marriage to co-accused Amarjeet Kumar on 9 July 2018, her husband and in-laws harassed her for dowry, including ₹6,50,000 and a Bullet motorcycle, and eventually left her at her parental home

The petitioners—her in-laws, but not her husband—sought to quash the Magistrate’s order dated 26 August 2022 taking cognizance under Sections 498A, 504 and 506 read with Section 34 of the Indian Penal Code (IPC), and Sections 3 and 4 of the Dowry Prohibition Act

They submitted that the allegations against them were general and omnibus

A supplementary affidavit established that the complainant and her husband had obtained a divorce by mutual consent and settled their claims and disputes.

The complainant was unrepresented; the State raised no objection to quashing.

1. Whether the criminal proceedings against the petitioners, who were the complainant’s in-laws and faced no specific allegations, should be quashed as an abuse of the process of the court

2. Whether the parties’ mutual-consent divorce and settlement supported quashing the proceedings against the petitioners

The prosecution arose under Sections 498A, 504, 506 read with Section 34 IPC and Sections 3 and 4 of the Dowry Prohibition Act.

Relying on Mange Ram v. State of Madhya Pradesh and Naushey Ali v. State of Uttar Pradesh, the Court noted that criminal proceedings arising from matrimonial disputes may be quashed following a compromise to bring the litigation to a peaceful conclusion.

It also relied on Kahkashan Kausar v. State of Bihar for the principle that continuing proceedings against in-laws on general or omnibus allegations may amount to abuse of the process of the court.

The Court considered that the petitioners were the complainant’s in-laws, not her husband, and that no specific allegations had been made against them.

It also took account of the mutual-consent divorce and the parties’ settlement of their claims concerning maintenance and permanent alimony.

In light of the settlement, the character of the allegations, and the State’s lack of objection, the Court concluded that continuing the prosecution against these petitioners would serve no useful or legitimate purpose and would amount to an abuse of process.