Omnibus matrimonial-cruelty allegations cannot sustain prosecution of relatives absent specific involvement.

Respondent No. 2, the wife of Petitioner No. 1 and daughter-in-law of Petitioner No. 2, married Petitioner No. 1 on 11 December 2021 at Arya Samaj Mandir, Jodhpur, Rajasthan.

She alleged that both petitioners subjected her to physical and mental cruelty for dowry, including demands for gold ornaments and ₹5,00,000; compelled her to terminate her pregnancy; sent her to her parental home; and subsequently refused to take her and her female child back after the child’s birth, while demanding an additional ₹2,00,000 and gold ornaments.

On her complaint to the Superintendent of Police, Jashpur, FIR Crime No. 204/2025 was registered at Police Station Kunkuri for offences under Sections 498-A and 34 IPC.

After investigation, the police filed a charge-sheet, and the trial court took cognizance on 5 May 2026.

The petitioners invoked the High Court’s inherent jurisdiction seeking quashing of the FIR, charge-sheet, cognizance order and consequential criminal proceedings.

Mediation failed despite Petitioner No. 1 depositing ₹1,00,000, which was handed over to Respondent No. 2.

Whether the FIR, charge-sheet, cognizance order and criminal proceedings for offences under Sections 498-A/34 IPC were liable to be quashed against both petitioners on the ground that the allegations were general and omnibus?

Whether the absence of specific allegations, dates, places or particulars of conduct against Petitioner No. 2, the mother-in-law, warranted quashing of the proceedings against her?

Whether the prosecution against Petitioner No. 1, the husband, should also be quashed in exercise of the High Court’s inherent jurisdiction?

The Court exercised its inherent jurisdiction under Section 528 BNSS/Section 482 CrPC to prevent abuse of the process of court.

Section 498-A IPC criminalises cruelty by the husband or his relatives, while Section 34 IPC concerns acts done in furtherance of common intention.

Relying on State of Haryana v. Bhajan Lal, the Court applied the principle that criminal proceedings may be quashed where the allegations, even if taken at face value, do not disclose a prima facie offence or continuation of the proceedings would amount to abuse of process.

Under Geeta Mehrotra v. State of Uttar Pradesh, K. Subba Rao v. State of Telangana, Rashmi Chopra v. State of Uttar Pradesh, Payal Sharma v. State of Punjab and Dara Lakshmi Narayan v. State of Telangana, relatives of the husband should not be prosecuted merely on the basis of their names or vague, sweeping and omnibus allegations; specific allegations indicating their active involvement are necessary.

Matrimonial complaints must therefore be scrutinised with caution to prevent harassment of relatives who are not shown to have participated in the alleged cruelty.

The Court found that the complaint contained only common and general allegations that both petitioners had demanded gold ornaments and ₹5,00,000 and had subjected Respondent No. 2 to cruelty, without specifying the date, place or individual acts attributable to Petitioner No. 2.

Applying the principles in Geeta Mehrotra, K. Subba Rao, Rashmi Chopra and Dara Lakshmi Narayan, the Court held that such bald and omnibus allegations did not establish a prima facie case under Section 498-A/34 IPC against the mother-in-law.

However, Petitioner No. 1 was the husband and the allegations directly concerned the matrimonial relationship and alleged conduct attributed to him.

The Court consequently declined to terminate the prosecution against him and directed that his trial proceed independently and in accordance with law.

Criminal Case No. 1542/2026 arising from Crime No. 204/2025 was quashed only insofar as it related to Petitioner No. 2, Prema Bai @ Prem Kuwar, the mother-in-law, as the FIR contained no specific allegations establishing her active involvement in the alleged cruelty.

The prosecution against Petitioner No. 1, Padam Singh @ Prayag Singh, was permitted to continue, and the trial court was directed to decide the case strictly in accordance with law without being influenced by the High Court’s observations.

No costs were awarded.