Vague and omnibus allegations against relatives in matrimonial disputes without specific overt acts warrant quashment.

The marriage between Respondent No. 2 (complainant) and Dhruv Singh Bhadauriya was solemnized on 11.05.2005.

The complainant alleged that her husband, mother-in-law (Petitioner 1), father-in-law (Petitioner 2), and sister-in-law (Petitioner 3) harassed her for additional dowry (a car and Rs. 5,00,000/-) and subjected her to physical and mental cruelty.

Consequently, FIR Crime No. 96/2021 was registered under Sections 498A, 506, 34 of the IPC and Section 4 of the Dowry Prohibition Act.

The petitioners sought quashment under Section 482 Cr.P.C., contending that the allegations were a counterblast to a property dispute regarding a house in Gwalior, from which the elderly petitioners were allegedly forcibly dispossessed in 2012.

They further argued that Petitioner 3 had been residing separately in different states since 2011.

Whether the allegations in the FIR and Section 161 Cr.P.C. statements, taken at face value, prima facie disclose the commission of the alleged offences against the petitioners.

Whether the continuation of criminal proceedings based on vague and omnibus allegations against the relatives of the husband constitutes an abuse of the process of law.

The court primarily applied Section 482 of the Cr.P.C. regarding the inherent powers of the High Court to prevent abuse of process and secure the ends of justice.

It relied on the principles established in Preeti Gupta v. State of Jharkhand (2010), emphasizing the need to scrutinize general and omnibus allegations against relatives.

It further applied Geeta Mehrotra v. State of Uttar Pradesh (2012), holding that FIRs lacking specific roles for relatives warrant quashment.

It applied Kahkashan Kausar @ Sonam v. State of Bihar (2022), which warned against proceeding against distant relatives without specific and distinct allegations.

The Court observed that the allegations against the petitioners were "general and omnibus in nature," lacking specific dates, times, or distinct overt acts.

Upon examining the record, the Court found that the complainant’s statements were sweeping assertions intended to exert pressure regarding a property dispute rather than specific instances of cruelty.

Regarding Petitioner 3 (sister-in-law), the Court noted she had been residing separately in various states (Assam, Karnataka, Delhi) since 2011 due to her husband's postings, yet no specific incident was attributed to her.

The Court reasoned that criminal proceedings cannot be sustained on bald assertions alone, as permitting such a trial would result in unnecessary harassment and a misuse of the criminal justice system.

The Court allowed the petition and quashed FIR No. 96/2021 (Police Station Mahila Thana, District Padav) and all consequential proceedings insofar as they related to the present petitioners.

The court concluded that maintaining the case would amount to an abuse of the process of the court.