Omnibus matrimonial allegations without specific roles cannot sustain prosecution of in-laws.

The complainant’s FIR alleged that, after her marriage to accused No. 1, her in-laws (the present applicants, accused Nos. 2–5) made dowry-related remarks and demands, subjected her to verbal mistreatment, and instigated her husband to ill-treat and eventually exclude her from the matrimonial home.

She alleged that she was required to bring ₹5 lakh from her parents.

The FIR, registered on 16 February 2021, invoked Sections 498A, 323, 504, 294(b) and 114 of the Indian Penal Code, 1860, and Sections 3 and 7 of the Dowry Prohibition Act, 1961.

The applicants sought quashing under Section 482 of the Code of Criminal Procedure, 1973, contending that the allegations against them were vague and that the complainant and accused No. 1 had settled their disputes and obtained a divorce decree on 18 September 2024.

The complainant did not appear despite service of notice.

1. Whether the FIR contained sufficiently specific allegations against applicants Nos. 2–5 to warrant continuation of the criminal proceedings against them

2. Whether the applicants’ prosecution should be quashed under Section 482 CrPC in light of the parties’ settlement and the subsequent divorce decree

Section 482 CrPC preserves the High Court’s inherent power to quash proceedings to prevent abuse of process or secure the ends of justice.

The Court applied the principle in Dara Lakshmi Narayana v. State of Bihar, (2025) 3 SCC 735, that merely naming family members in a matrimonial-dispute prosecution, without specific allegations showing their active involvement, is insufficient to sustain prosecution; vague and sweeping accusations warrant judicial caution.

The FIR also invoked Sections 498A, 323, 504, 294(b) and 114 IPC and Sections 3 and 7 of the Dowry Prohibition Act, 1961.

The Court found that the allegations against applicants Nos. 2 and 3 principally concerned alleged instigation and remarks about dowry, while those against applicants Nos. 4 and 5 were general allegations about clothing, household work, abusive language and instigation.

It considered these allegations omnibus and lacking a specific role, time or place; the alleged dowry demand was also not tied to a date or time or to a proximate act by the applicants.

Applying Dara Lakshmi Narayana, the Court concluded that the allegations did not disclose a sufficient basis to prosecute these applicants.

It also took account of the parties’ settlement, the withdrawal arrangement recorded in the matrimonial proceedings, and the divorce decree, and held that continuing the investigation against the applicants would amount to abuse of process.

The rule was made absolute to that extent; the order did not quash proceedings against accused No. 1.