### Quashing of FIR Permissible for Distant Relatives Named via Vague, Omnibus Allegations Without Specificity

The informant, Megha Singh (O.P. No. 2), married Ankit Singh in 2017.

She alleged that shortly after, her in-laws began torturing her over dowry demands.

The FIR, Nayagaon P.S. Case No. 184 of 2024, was registered under several sections of the BNS and the Dowry Prohibition Act, naming 11 accused persons, including distant relatives and married sisters-in-law.

Allegations included mental harassment, physical assault with a knife by Sweta Singh (Petitioner 7), attempted sexual abuse by the father-in-law and a cousin brother-in-law, and attempts to forcibly take her child for adoption.

The petitioners sought quashing of the FIR, arguing they were falsely implicated as distant relatives living separately.

1. Whether the FIR against the petitioners warrants quashing under Section 482 of the Cr.P.C. (or relevant BNS provisions) on the grounds of being frivolous or involving vague and omnibus allegations?

2. Whether the court can embark upon an inquiry into the reliability of allegations while the police investigation is still pending?

The court primarily applied the principles of Section 482 Cr.P.C. regarding the inherent powers of the High Court to prevent abuse of the process of law.

It relied on the landmark precedent of *State of Haryana & Ors. v. Bhajan Lal*, which establishes that an FIR can be quashed if the allegations, even if taken at face value, do not disclose a cognizable offence.

It further applied the "rarest of rare cases" doctrine for quashing as reiterated in *Neeharika Infrastructure Private Limited v. State of Maharashtra*, emphasizing that courts should not thwart investigations or conduct "mini-trials" at the threshold stage.

The court scrutinized the FIR to distinguish between specific and vague allegations.

It found that for most petitioners (Nos. 1, 3, 6, 7, 8 in Cr. Misc. 75805 and both in Cr. Misc. 75931), the informant provided specific instances of abuse, including dates and roles in harassment or attempted abduction of the child.

Consequently, the court held that their defense of "separate living" is a matter of trial and cannot be adjudicated at the FIR stage without preempting the investigation.

However, regarding Petitioners No. 2 (Manisha Singh), 4 (Krishna Kumar Singh), and 5 (Sweta Singh), the court observed that the allegations were "very vague and omnibus" in nature, lacking the specificity required to sustain a criminal prosecution.

Applying the *Bhajan Lal* criteria, the court determined that continuing proceedings against these three individuals would amount to an abuse of process.

It quashed the FIR (Nayagaon P.S. Case No. 184 of 2024) specifically as against Petitioners No. 2 (Manisha Singh), 4 (Krishna Kumar Singh), and 5 (Sweta Singh) in Cr. Misc. No. 75805 of 2024.

The prayer for quashing was dismissed regarding all other petitioners, as the court found prima facie allegations necessitating further investigation.

The court clarified that petitioners remain at liberty to challenge subsequent developments after the filing of the charge-sheet.