Specific allegations disclosing a prima facie offence cannot be quashed under Section 482.

Respondent No. 2, Smt. Sanjana @ Sanju Dubey, married Ramji Dwivedi on 21 February 2025. The petitioners were her sister-in-law (jethani) and brother-in-law (jeth), allegedly residing separately with their children in another portion of the same house. Crime No. 587/2025 was registered at Police Station Kotwali, District Chhatarpur, on 10 September 2025 for offences under Sections 85, 296, 115(2), 351(3) and 3(5) of the Bharatiya Nyaya Sanhita, 2023, and Sections 3 and 4 of the Dowry Prohibition Act.

The petitioners sought quashing of the FIR and consequential proceedings under Section 482 of the Code of Criminal Procedure/Section 528 of the Bharatiya Nagarik Suraksha Sanhita, contending that they had been falsely implicated through omnibus allegations and that prior complaints had been made by the father-in-law, husband and mother-in-law alleging that respondent No. 2 threatened to lodge false cases.

The State opposed the petition, relying on specific allegations that the petitioners assaulted respondent No. 2 in connection with dowry demands and on the medical report recording injuries.

The FIR and the statement under Section 161 CrPC alleged that, on 9 September 2025, the petitioners abused and assaulted respondent No. 2 with kicks and fists, causing injuries; the FIR was lodged the following day.

Whether the FIR and consequential criminal proceedings against the petitioners disclosed a prima facie case warranting investigation and trial, or were liable to be quashed under Section 482 CrPC/Section 528 BNSS.

Whether the petitioners could rely on their defence that they lived separately, had been falsely implicated, and that prior complaints had been made against respondent No. 2 to seek quashing at the threshold.

Whether the High Court could assess the truth, reliability or evidentiary value of the allegations and medical material while exercising its inherent jurisdiction.

The Court applied the inherent jurisdiction under Section 482 CrPC/Section 528 BNSS, which may be exercised sparingly to prevent abuse of process or secure the ends of justice.

Relying principally on Supriya Jain v. State of Haryana, Amit Kapoor v. Ramesh Chander, Gulam Mustafa v. State of Karnataka, State of Haryana v. Bhajan Lal, CBI v. Aryan Singh, Abhishek v. State of M.P., Mahendra K.C. v. State of Karnataka and Iveco Magirus Brandschutztechnik GMBH v. Nirmal Kishore Bhartiya, the Court held that quashing is justified only where the allegations, taken at face value, do not disclose an offence, are inherently improbable, or the proceedings are manifestly abusive or barred by law.

The Court must not conduct a mini-trial, assess the reliability of evidence, consider the accused’s external defence materials, or determine whether conviction is likely; where the factual foundation of an offence is prima facie established, the prosecution should ordinarily continue.

The FIR and the Section 161 statement contained specific allegations that the petitioners assaulted respondent No. 2 with kicks and fists in connection with dowry-related abuse, and the MLC recorded injuries on her body.

These allegations, if accepted at face value, disclosed the essential factual foundation of the offences alleged and were neither inherently absurd nor incapable of being proved.

The petitioners’ assertions regarding separate residence, prior complaints against respondent No. 2, and false implication constituted matters of defence and evidence.

In view of the settled limitation against examining disputed facts or conducting a mini-trial under Section 482 CrPC, the Court declined to evaluate those assertions at the threshold.

Since the allegations were not shown to be false or baseless at the preliminary stage and were supported prima facie by the MLC, no interference under Section 482 CrPC/Section 528 BNSS was warranted.

The petition was dismissed as meritless.

The Court clarified that its observations were confined to the disposal of the petition and would not affect the trial, which was directed to proceed uninfluenced by those observations and in accordance with law.