Court’s Decision
The Chhattisgarh High Court, in its order dated 09.06.2025, quashed the criminal proceedings against the in-laws (petitioner nos. 2 and 3) of the complainant under Section 498A/34 IPC, observing that there were no specific allegations against them. The Court held that:
“In the complaint so made, the complainant has only made omnibus and general allegations… There is no specific allegation regarding anyone of the petitioners except common and general allegations…”
However, the criminal prosecution against the husband (petitioner no. 1) was directed to continue and is to be decided independently on its own merits.
Facts
The petitioners challenged the FIR No. 415/2024 registered on 31.08.2024 at Police Station Balconagar, District Korba under Sections 498A and 34 IPC. The complaint, filed by the wife, alleged that the marriage took place on 28.11.2022, during which there was a dowry demand of ₹11 lakhs. ₹4 lakhs was allegedly transferred to petitioner no. 2 prior to the wedding. Initially, relations were cordial, but the complainant claimed that she was subsequently harassed and assaulted for not bringing sufficient dowry and household items. On 13.04.2024, ₹30,000 was further deposited by her father in petitioner no. 2’s account. The complainant alleged that she was beaten and locked up in her aunt-in-law’s home until rescued by her parents. Despite attempts at mediation and counselling, the dispute remained unresolved, leading to registration of the FIR.
Issues
- Whether the FIR and consequent proceedings under Section 498A/34 IPC could be sustained against the in-laws (petitioners no. 2 and 3) in the absence of specific allegations?
- Whether the continuation of the proceedings amounted to abuse of process?
Petitioners’ Arguments
The petitioners submitted that the FIR was the result of a matrimonial dispute between petitioner no. 1 (husband) and the complainant. They contended that petitioners no. 2 and 3 (in-laws) were falsely implicated without any specific allegations, and the complaint consisted of omnibus and generalised accusations. It was further argued that the matter was earlier referred to mediation in connection with the husband’s bail application (MCRCA No. 1187/2024), and ₹1,00,000 had already been deposited with the Mediation Centre.
Respondent’s Arguments
The respondent no. 3 (wife), through counsel, submitted that the mediation process had failed despite withdrawal of the ₹1,00,000 deposited by petitioner no. 1. It was urged that there existed sufficient material in the complaint to justify the registration of the FIR and the continuation of proceedings.
Analysis of the Law
The Court carefully analysed whether the complaint disclosed a prima facie case under Section 498A/34 IPC. It was noted that the allegations against petitioners no. 2 and 3 were vague, generalised, and lacked specific dates or details of any particular incident. The FIR merely stated that they misbehaved and made dowry-related taunts, without distinguishing individual roles.
Precedent Analysis
The Court relied heavily on several Supreme Court judgments:
- Geeta Mehrotra v. State of U.P. (2012) 10 SCC 741 – Held that mere casual reference to family members without specific allegations does not justify prosecution.
- K. Subba Rao v. State of Telangana (2018) 14 SCC 452 – Emphasised caution while proceeding against distant relatives in matrimonial cases based on omnibus allegations.
- Rashmi Chopra v. State of U.P. (2019 SCC OnLine SC 620) – Reiterated that sweeping allegations without specificity do not establish a case under Section 498A IPC.
- Payal Sharma v. State of Punjab (Cr.A. No. 4773/2024) – The Court quashed proceedings on the ground that the FIR was used as a counterblast to matrimonial proceedings and lacked specific allegations.
- Dara Lakshmi Narayan v. State of Telangana (Cr.A. No. 5199/2024) – Warned against misuse of Section 498A IPC through generalised complaints and called for scrutiny of vague accusations.
- G.V. Rao v. L.H.V. Prasad (2000) 3 SCC 693 – Cautioned that matrimonial skirmishes should not lead to prolonged litigation involving elders of the family.
- Preeti Gupta v. State of Jharkhand (2010) 7 SCC 667 – Stressed the need for courts to adopt a pragmatic approach in such cases and avoid unnecessary harassment of relatives not residing in the matrimonial home.
Court’s Reasoning
The Court found that the allegations in the FIR were “bald and omnibus” and lacked any specific attribution of cruelty or harassment by petitioners no. 2 and 3. It noted that:
“There is no specific allegation regarding anyone of the petitioners except common and general allegations against all…”
The Court accepted that generalised accusations unsupported by specific factual assertions could not sustain a prosecution under Section 498A IPC.
Conclusion
The High Court allowed the petition under Section 482 CrPC in part. The Court quashed the FIR, chargesheet, and entire proceedings in Criminal Case No. 5758/2024 pending before the Judicial Magistrate First Class, Korba, to the extent it concerned petitioner nos. 2 and 3. The proceedings against petitioner no. 1 (husband) were permitted to continue.
Implications
This judgment reaffirms judicial caution in permitting prosecutions under Section 498A IPC based solely on omnibus allegations. It underscores the obligation of courts to prevent misuse of the criminal justice process and shields innocent relatives from unwarranted harassment. The ruling is particularly significant in the context of matrimonial disputes where it is common to implicate entire families.
