Omnibus matrimonial allegations without specific roles cannot sustain prosecution of the husband’s relatives.

Sima Kumari alleged that, after her marriage to petitioner No. 1’s son, she was subjected to cruelty and dowry harassment, including a demand for a car, and was driven from the matrimonial home.

She also alleged that the accused abused and assaulted her at her parental home on 12 July 2015.

She filed a complaint alleging offences under Section 498A of the Indian Penal Code (IPC) and Section 4 of the Dowry Prohibition Act, 1961.

The Sub-Divisional Judicial Magistrate took cognizance of those offences against the petitioners on 11 March 2016; the Sessions Judge dismissed their revision on 31 August 2016.

The petitioners sought quashing under Section 482 of the Code of Criminal Procedure, 1973 (CrPC), contending that the allegations against them—her father-in-law, mother-in-law and maternal uncle-in-law—were general and omnibus.

Whether the complaint and inquiry statements disclosed specific allegations against each petitioner sufficient to constitute an offence under Section 498A IPC.

Whether the allegations concerning a dowry demand disclosed a sufficient basis to proceed against the petitioners under Section 4 of the Dowry Prohibition Act.

Whether continuation of the proceedings against the petitioners amounted to an abuse of process warranting relief under Section 482 CrPC.

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

Section 4 of the Dowry Prohibition Act addresses demanding dowry.

Under Section 482 CrPC, the High Court may quash proceedings to prevent abuse of process or secure the ends of justice; although it ordinarily does not conduct a detailed assessment of evidence, it may intervene where allegations taken at face value do not disclose the offence alleged.

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

It also cited Arti Mehta v. State of Madhya Pradesh, 2026 SCC OnLine SC 933, for the need to scrutinise whether allegations disclose an offence against each accused.

The Court considered the complaint and inquiry statements and found that, although they referred generally to dowry demand and cruelty, they did not specify what conduct was attributable to each petitioner or establish their individual participation in the alleged offences.

The reference to a demand for a car did not provide sufficient particulars of each petitioner’s involvement to support the charge under Section 4 of the Dowry Prohibition Act.

Applying the principles governing omnibus allegations against a spouse’s relatives, the Court concluded that the complaint did not disclose the necessary ingredients of the offences against these petitioners and that continuing the prosecution against them would constitute an abuse of process.

It quashed the Sessions Judge’s order dated 31 August 2016 and the Magistrate’s cognizance order dated 11 March 2016, together with the criminal proceedings arising from them, qua the petitioners.