Prosecution under Sections 498-A and 120-B cannot rest on omnibus allegations against in-laws.

Ruby Devi complained that, following her 1999 marriage, her husband’s relatives demanded ₹50,000 and subjected her to cruelty; she also alleged that on 13 May 2008 they assaulted her, took her ornaments and clothes, and attempted to kill her by sprinkling kerosene.

After an inquiry, the Judicial Magistrate took cognizance and issued process against the petitioners under Sections 498-A and 120-B IPC on 2 September 2008.

The petitioners sought quashing under Section 482 CrPC, contending that the complaint arose from a family-property dispute, that allegations against them were general and vague, and that a partition settlement had been reached before the Permanent Lok Adalat.

The State opposed quashing; the complainant did not appear at the hearing.

1. Whether the complaint and inquiry materials disclosed sufficiently specific allegations against the petitioners to support cognizance under Section 498-A IPC.

2. Whether the materials disclosed an agreement or meeting of minds sufficient to make out criminal conspiracy under Section 120-B IPC.

3. Whether continuation of the criminal proceedings against the petitioners would amount to an abuse of process warranting relief under Section 482 CrPC.

Section 498-A IPC criminalises a husband or his relative’s subjection of a woman to “cruelty,” including specified wilful conduct and harassment connected with an unlawful demand; matrimonial discord alone does not establish the offence, and the allegations must disclose its ingredients against the particular accused.

Section 120-B IPC requires an agreement between two or more persons to commit an illegal act or to achieve a lawful object by illegal means; the agreement may be inferred from circumstances, but must be supported by material.

Under Section 482 CrPC, the High Court may quash proceedings where, even accepting the allegations at face value, the necessary ingredients of the offences are absent or continuation would constitute an abuse of process.

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 lacking specific instances of involvement.

The Court relied on *Rajeev v. State of Kerala*, 2023 SCC OnLine SC 1470, referring to *State through Superintendent of Police, CBI/SIT v. Nalini*, (1999) 5 SCC 253, concerning the elements of criminal conspiracy.

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

The Court found that the complaint and inquiry statements made generic allegations of cruelty but did not adequately identify the individual conduct of each petitioner.

It considered the petitioners’ account of the family-property dispute and partition settlement, alongside the complaint’s allegations, and concluded that the materials did not disclose an agreement among the petitioners to commit an illegal act; the partition settlement alone did not establish conspiracy.

In the Court’s view, the allegations therefore failed to establish the necessary ingredients of Sections 498-A and 120-B IPC against the petitioners, and continuation of the proceedings would amount to abuse of process.

It quashed the Magistrate’s order dated 2 September 2008 taking cognizance under Sections 498-A and 120-B IPC, together with the consequential criminal proceedings, insofar as they concerned the petitioners.