Quashing of FIR against relatives for general and omnibus allegations in matrimonial disputes to prevent abuse of process.

The petitioners (mother-in-law, sister-in-law, and brother-in-law of the informant) sought the quashing of FIR Mahila P.S. Case No. 05 of 2022.

The marriage between the informant (O.P. No. 2) and the petitioners' relative occurred in 2006.

After 16 years of marriage and having three children, the informant alleged harassment, dowry demands for a Delhi flat, and cruelty under Sections 341, 323, 498A, 406, 494, and 506/34 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act.

The petitioners argued that the allegations were general and omnibus, pointing out that Petitioner No. 3 resides abroad and Petitioners No. 1 and 2 reside in a native village, while the husband works in Qatar.

Till the date of judgment, no charge-sheet had been filed.

1. Whether the criminal proceedings against the in-laws (relatives of the husband) should be quashed on the grounds that the allegations are general, omnibus, and an abuse of the process of law.

Section 482 of the CrPC regarding the inherent powers of the High Court to prevent abuse of the process of any court.

The precedent set in Kahkashan Kausar & Ors. v. State of Bihar & Ors. (2022) 6 SCC 599, which cautioned against the misuse of Section 498A IPC to implicate relatives through general and sweeping allegations.

Dara Laxmi Narayana v. State of Telangana (2025) 3 SCC 735 and Mange Ram v. State of Madhya Pradesh & Anr. (2025) INSC 962, which established that roping in family members without specific accusations in matrimonial discords serves no legitimate purpose.

The court observed that the marriage held for 16 years before the FIR was lodged, suggesting the implication of the petitioners was an "over-implication" following matrimonial discord between the husband and wife.

Upon reviewing the FIR and counter-affidavits, the court found the allegations against the petitioners to be general, omnibus, and casual, such as "sarcastic and derogatory remarks" and vague pressure regarding a flat.

The court noted the primary grievance of the informant was directed at her husband (specifically regarding an alleged illicit relationship and a second marriage), yet the entire family was dragged into the dispute.

Applying the principles from Kahkashan Kausar, the court reasoned that forcing relatives to undergo the rigors of a trial based on such sweeping allegations would be unjust and a misuse of the legal machinery.

The court allowed the application and quashed the criminal proceedings arising out of Mahila P.S. Case No. 05 of 2022 specifically against the three petitioners, while clarifying that proceedings shall continue against the husband.