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2026 Supreme(Kar) 5

IN THE HIGH COURT OF KARNATAKA AT BENGALURU
M.NAGAPRASANNA, J.
Vimala N. W/o D. Nagaraju – Appellant
Versus
The State of Karnataka – Respondent
Criminal Petition No. 4025 of 2023
Decided On : 06-01-2026

Advocates Appeared:
Fort the Appellant : Sukanya H.D.
For the Respondents: K. Nageshwarappa, Roshan M.C.

Vague or generalized allegations in matrimonial disputes do not support criminal proceedings under IPC and Dowry Prohibition Act, necessitating specific instances for valid charges.

Headnote:(A) Indian Penal Code, 1860 - Sections 498A, 323, 504, 506, 114, 149 - Dowry Prohibition Act, 1961 - Sections 3 and 4 - Petitioners, distant relatives of accused, challenged registration of crime for allegations involving instigation. Court found allegations vague and lacking specifics, quashed proceedings against petitioners. (Paras 2, 8, 26)

(B) Legal Principles - Criminal proceedings must be based on specific, tangible allegations rather than general or vague accusations. Courts should scrutinize matrimonial complaints rigorously to prevent misuse of legal remedies. (Paras 23, 27)

Facts of the case:
Petitioners, accused Nos.4 and 5, sought to quash proceedings in Crime No.92/2023 under IPC and Dowry Prohibition Act for allegations of instigation lacking detailed support, with settlement reached by parties. (Paras 3, 5)

Findings of Court:
Absence of specific allegations against petitioners signifies no offence made out, thus proceedings were quashed. (Paras 26, 9)

Issues: Whether vague allegations suffice for legal action under IPC regarding cruelty and dowry-related charges? (Para 22)

Ratio Decidendi: Mere generalized claims do not substantiate criminal action; thus, lack of clear allegations leads to quashing of cases to prevent legal process abuse. (Paras 24, 30)

Result: Criminal petition allowed; proceedings quashed against petitioners.

Table of Content
1. allegations of crime registration. (Para 1 , 3)
2. arguments regarding instigation allegations. (Para 4 , 5 , 7)
3. final order of petition allowance. (Para 9)

ORDER :

1. The petitioners are before this Court calling in question registration of a crime in Crime No.92/2023 registered for the offences punishable under Sections 498A, 323, 504, 506, 114, 149 of the Indian Penal Code, 1860 ('the IPC' for short) and Sections 3 and 4 of the Dowry Prohibition Act, 1961.

2. Heard Smt. Sukanya H.D. learned counsel appearing for the petitioners; Sri. K. Nageshwarappa, learned High Court Government Pleader appearing for respondent No.1 and Sri. Roshan M.C., learned counsel appearing for respondent No.2.

3. The petitioners are accused Nos.4 and 5, distant relatives of accused Nos.1, 2 and 3. Respondent No.2 is the complainant. The complainant and accused No.1 get married on 11.12.2022. It transpires that soon after marriage, the relationship between accused No.1 and the complainant flounders. On floundering of the relationship, respondent No.2-complainant registers a crime, which becomes a crime in Crime No.92/2023 for the afore-quoted offences. The petitioners are also dragged into the web of crime. The dragging of the petitioners into the web of crime is what has driven these petitioners to this Court in the subject petition.

4. This Court had protected the interests of these petitioners by passing the following order:

"Learned High Court Government Pleader is directed to accept notice for respondent No.1. Learned counsel for the petitioners to serve a copy of the petition papers upon the learned High Court Government Pleader, forthwith.

Issue emergent notice to respondent No.2.

ORDER ON I.A. NO. 1 OF 2023

The petitioner is before this Court calling in question proceedings in Crime No.92 of 2023 registered for offences punishable under Sections 498A, 323, 504, 506, 114 and 149 of the IPC and also under Sections 3 and 4 of the Dowry Prohibition Act, 1961.

The complainant in the complaint narrates all the allegations against the husband, mother-in-law and father-in-law. Insofar as the petitioners are concerned the only allegation is that they have instigated all the three to torture the complainant.

Such instigation without anything in detail cannot lay a foundation against the petitioners, in particular for offences punishable under Section 498A of the IPC and other offences.

Therefore, finding all allegations against accused Nos.1 to 3, there shall be an interim order of stay of all further proceedings in Crime No.92 of 2023, against the petitioners/accused Nos.4 and 5, till the next date of hearing. I.A.No.1 of 2023 is allowed."

The interim order is in subsistence even as on date.

5. The learned counsel appearing for the petitioners submits that the petitioners are distant relatives and did not reside with the couple at any point in time and therefore, none of the ingredients of the offences are even present in the case at hand qua the petitioners. The learned counsel further contends that the parties to the lis have settled the dispute in MC.No.2/2024 by drawing up terms of settlement on 28.11.2025. It also recognises the closure of these proceedings.

6. The learned counsel appearing for the respondents would not dispute the position of settlement between the parties.

7. Be that as it may. Settlement or otherwise, the offences against these petitioners as found in the complaint is as follows:

Barring this allegation against these petitioners, there is nothing that is alleged. If this be the allegation against these petitioners, it would only be an omnibus allegation of instigation to the family of the husband or the family of the husband to act in a particular manner against the wife.

8. The added circumstance is that the parties to the lis have settled the dispute amongst themselves in an MC.No.2/2024 on 28.11.2025. With all these being the case and also finding no allegation that would touch upon the ingredients of the offences under

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