Vague, omnibus allegations of matrimonial discord lacking specific overt acts do not constitute "cruelty" under Section 498A.

The applicants (husband and his relatives) sought the quashing of FIR C.R. No. II-173 of 2016 filed by the respondent-wife at Mahila Police Station, Rajkot

The complainant alleged physical and mental cruelty, dowry harassment, and desertion

During the pendency of these proceedings, the marriage was dissolved by the Family Court, Surat (Suite No. 25 of 2020) on 28.08.2026 on grounds of non-compliance with a decree for restitution of conjugal rights

The applicants argued that the FIR consisted of vague and omnibus allegations reflecting ordinary matrimonial discord rather than criminal cruelty

1. Whether the allegations in the FIR, taken at face value, disclose the commission of offences under Sections 498A, 323, and 114 of the Indian Penal Code

2. Whether the continuation of criminal proceedings constitutes an abuse of the process of law in light of the subsequent dissolution of marriage and the nature of the allegations

The court applied Section 482 of the Code of Criminal Procedure, 1973, concerning the inherent powers of the High Court to quash proceedings to prevent abuse of process

Section 498A of the IPC (Cruelty), specifically the definition requiring "wilful conduct" likely to drive a woman to suicide or cause grave injury, or harassment for unlawful property demands

The court further cited Shobhit Kumar Mittal v. State of Uttar Pradesh & Anr. (2025) and Ghanshyam Soni v. State (NCT of Delhi) (2025), which established that "omnibus allegations" against multiple relatives without specific overt acts or concrete evidence cannot justify prosecution under Section 498A

The court found that a plain reading of the FIR revealed allegations that were vague, general, and omnibus in nature

The court noted that the descriptions of quarrels over trivial issues and minor differences of opinion constituted the "ordinary wear and tear of matrimonial life" rather than "cruelty" as legally defined under Section 498A

Applying the principles from Ghanshyam Soni, the court observed that the complainant failed to attribute specific roles or time-bound events to the applicants

Furthermore, the court considered the subsequent development where the marriage was legally dissolved by a Family Court decree that had attained finality, indicating the end of the matrimonial discord

Consequently, both applications were allowed, and the FIR (C.R. No. II-173 of 2016) along with all consequential proceedings were quashed and set aside against the applicants to prevent the abuse of the judicial process

Rule was made absolute