Vague and omnibus allegations against separately residing relatives in matrimonial disputes constitute an abuse of process.

The petitioners (sister-in-law and brother-in-law of the complainant) sought quashment of FIR No. 40/2025 registered at Mahila Thana, Gwalior, for offences under Sections 85, 296, 351(3), 333, 3(5), and 115(2) of the Bhartiya Nyaya Sanhita (BNS), 2023, and Section 4 of the Dowry Prohibition Act.

The complainant alleged that following her marriage to Puneet Gupta in March 2023, her husband and in-laws (including the petitioners) subjected her to physical and mental cruelty over demands for a car and ₹50,00,000.

Specific to the petitioners, it was alleged they lived nearby and frequently visited to instigate the husband and parents-in-law to pressure her for more dowry.

The petitioners contended they have lived in a separate matrimonial home since 2020 and that the allegations were vague and omnibus.

1. Whether the allegations against the petitioners in the FIR and charge-sheet disclose the commission of a cognizable offence or are merely vague and omnibus in nature.

2. Whether the continuation of criminal proceedings against the married sister-in-law and her husband, who reside separately, constitutes an abuse of the process of law.

The court primarily applied the inherent powers under Article 226 of the Constitution of India to prevent the abuse of the process of law.

It relied on the landmark principles from *State of Haryana v. Bhajan Lal*, 1992 Supp (1) SCC 335, which established categories where High Courts may quash proceedings if allegations are manifestly vague or fail to disclose essential ingredients of an offence.

Furthermore, the court applied the precedents of *Kahkashan Kausar @ Sonam v. State of Bihar* (2022) 6 SCC 599, *Preeti Gupta v. State of Jharkhand* (2010) 7 SCC 667, and *Geeta Mehrotra v. State of U.P.* (2012) 10 SCC 741, which caution against roping in distant relatives in matrimonial disputes through generalized allegations without specific overt acts.

The court observed that the allegations against the petitioners—specifically that they "instigated" the primary accused—were entirely general and lacked particulars regarding date, time, or specific conduct.

The court noted that Petitioner No. 1 had been married and living separately since 2020, long before the complainant’s marriage, making her continuous involvement improbable.

Applying the *Kahkashan Kausar* doctrine, the court found that the prosecution failed to provide independent or corroborative material beyond the "reiteration" of the complainant’s statement by her parents under Section 161 Cr.P.C.

The court reasoned that since the allegations lacked the essential ingredients of the alleged offences and appeared to be a result of the tendency to implicate all of the husband's relatives, permitting the trial to proceed would result in unwarranted harassment.

The court allowed the petition and quashed FIR No. 40/2025, the resulting charge-sheet, and the consequential proceedings (RCT No. 1026/2025) specifically regarding the two petitioners.

The court ordered that proceedings against the husband and parents-in-law shall continue unaffected.