Vague and omnibus allegations against matrimonial relatives without specific overt acts constitute an abuse of process.

The petitioners (the husband, brother-in-law, sister-in-law, and mother-in-law of the complainant) sought to quash FIR CR No. 11202036220594 of 2022 registered at Lalpur Police Station, Jamnagar, alleging offences under Sections 498(A), 323, 504, 506(2), and 114 of the IPC.

The complainant alleged that the relatives (petitioners 2-4) instigated her husband to harass her and send her back to her parents.

During the pendency of the petition, Petitioner No. 1 (the husband) died on 19.10.2023.

The court observed that the mother-in-law resided separately with the brother-in-law, and the allegations against the extended family were non-specific.

1. Whether the criminal proceedings against Petitioner No. 1 (husband) survive following his death.

2. Whether the allegations in the FIR against Petitioner Nos. 2, 3, and 4 meet the legal threshold for "cruelty" under Section 498(A) of the IPC or constitute an abuse of the process of law.

Section 482 of the Code of Criminal Procedure (inherent powers to quash proceedings to prevent abuse of process) and Section 498(A) of the Indian Penal Code.

The Court relied heavily on the precedent of Dara Lakshmi Narayana v. State of Bihar (2025) 3 SCC 735, which held that vague and omnibus allegations against a husband’s family members in matrimonial disputes, without specific evidence of active involvement, should be "nipped in the bud" to prevent misuse of the legal process.

The Court noted that the petition qua Petitioner No. 1 stood abated due to his death.

Regarding the remaining petitioners, the Court found that the allegations were general, vague, and lacked specific dates, times, or incidents.

The Court observed a tendency in matrimonial disputes to implicate all family members through "sweeping accusations".

It highlighted that the specific allegations of physical injury and intoxication were directed solely at the deceased husband, whereas the relatives lived separately or were only alleged to have used "abusive language" or "instigated" the husband.

The Court reasoned that even if the allegations were taken at face value, they did not satisfy the legal definition of cruelty under Section 498(A) and thus proceeding would be an abuse of the judicial system.

Regarding Petitioner Nos. 2, 3, and 4, the Court allowed the application, quashing FIR CR No. 11202036220594 of 2022 and all consequential proceedings, including Criminal Case No. 1729 of 2022.

The Court concluded that the FIR lacked material facts and was an abuse of the criminal machinery.

Rule was made absolute.