Vague and omnibus allegations lacking specific instances of cruelty cannot sustain criminal prosecution under Section 498-A.

The Petitioner No. 1 (husband) and Respondent No. 2 (wife) were married on 22.02.2015

The wife resided at the matrimonial home for a short period, living primarily at her parental home between 2015 and 2019 for education and later for professional employment

Following a separation starting in April 2022, Petitioner No. 1 filed a divorce petition on 16.05.2025

On 23.07.2025, the wife lodged a complaint leading to FIR No. 59/2025 under Sections 498-A and 34 of the IPC against the husband and his aged parents (Petitioners No. 2 and 3)

A charge-sheet was filed on 30.10.2025, and the Judicial Magistrate First Class, Durg, took cognizance on 31.10.2025

The petitioners moved the High Court to quash the proceedings, alleging they were a malicious counterblast to the divorce petition

1. Whether the FIR and consequential criminal proceedings against the petitioners are liable to be quashed under Section 528 of the B.N.S.S. as an abuse of the process of law

2. Whether the allegations in the FIR constitute "cruelty" under Section 498-A IPC or are merely vague, omnibus allegations intended to harass the husband’s relatives

Section 528 of the Bhartiya Nagarik Suraksha Sanhita (B.N.S.S.) regarding the High Court's inherent power to quash proceedings to prevent abuse of process

Section 498-A of the IPC concerning cruelty by a husband or his relatives

The court relied on the landmark principles in State of Haryana v. Bhajan Lal, which identified categories for quashing, including cases of mala fide intent or where allegations do not disclose an offence

It applied the doctrine from Kahkashan Kausar alias Sonam v. State of Bihar and Preeti Gupta v. State of Jharkhand, which cautioned against roping in relatives through general and omnibus allegations in matrimonial disputes

It cited Charul Shukla v. State of UP regarding the misuse of Section 498-A as a counterblast to divorce proceedings

The court found that the wife had resided separately for the majority of the marriage due to her professional pursuits, making the allegations of continuous cruelty inherently improbable

It observed that the FIR contained only "vague, omnibus allegations" regarding taunts over dowry quality and food preparation, without attributing specific roles to the in-laws

The court noted a significant delay, as the wife left the matrimonial home in 2022 but filed the complaint only in mid-2025, shortly after the husband initiated divorce proceedings

The court determined that the criminal machinery was jump-started with mala fide intent to settle personal scores

Applying the Bhajan Lal criteria, the court concluded that the case fell under categories 1, 3, and 7, as the uncontroverted allegations did not prima facie disclose an offence and the proceedings were maliciously instituted for vengeance

The High Court allowed the petition and quashed FIR No. 59/2025, the final report No. 66/2025, and the criminal proceedings in Case No. RCC/34782/2025 pending before the Judicial Magistrate First Class, Durg, against all petitioners