Matrimonial disputes require specific allegations for prosecution; vague accusations may result in quashing of proceedings to prevent misuse of legal processes.

ORDER :

1. This Criminal Petition is filed by the petitioners-accused Nos.2 to 5 seeking to quash the proceedings against them in C.C.No.920 of 2024 on the file of I Additional Judicial Magistrate of First Class at Karimnagar. The offences alleged against the petitioners are under section 498-A, 323, 506 r/w 149 of Indian Penal Code (for short ‘IPC’) and Sections 3 and 4 of Dowry Prohibition Act (for short ‘The Act’).

2. Heard Mr.G.Madhusudhan Reddy, learned counsel for the petitioners-accused Nos.2 to 5, Ms.V.Vaishali, learned counsel for respondent No.2 and Sri M.Ramachandra Reddy, learned Additional Public Prosecutor for the State. Perused the record.

3. The brief facts of the case are that the accused No.2 is the father-in-law, accused No.3 is the mother-in-law, accused No.4 is the sister-in-law, and accused No.5 is the husband of the sister- in-law. The 2^nd respondent/de-facto complainant married accused No.1, the son of accused Nos.2 and 3, on 06.12.2020 according to Hindu customs. After marriage, all the accused allegedly harassed the complainant both mentally and physically, demanding additional dowry. It is also alleged that accused No.1 developed bad habits such as drinking alcohol and assaulted the complainant, suspecting her fidelity, influenced by the other accused. Consequently, the complainant filed a case against them for offences under Sections 498-A, 323, 506 read with 149 of the Indian Penal Code (IPC) and Sections 3 and 4 of the Dowry Prohibition Act.

4. Learned counsel for the petitioners submits that there are no specific allegations against the petitioners-accused Nos.2 to 5 and only omnibus and vague allegations are made against the parents, sister and brother-in-law of accused No.1. It is further submitted that respondent No.2 has filed this false case with an ulterior motive to harass the petitioners by implicating them in the present case. Further, no dates of alleged harassment were mentioned either in the complaint or in the charge sheet. Further, the marriage of respondent No.2 was performed in the year, 2020 and she never shared roof with petitioner Nos.3 and 4 and left the company of the accused No.1 on 28.10.2022 and with a malafide intention, to harass the petitioners, lodged a complaint on 10.07.2023. There was endless harassment from respondent No.2, due to which the health of petitioner Nos.1 and 2 and avocation of petitioner Nos.3 and 4 are spoiled.

5. While seeking to quash the criminal proceedings against the petitioners, learned counsel for the petitioners relied upon a decision in Dara Lakshmi Narayana and others v. State of Telangana and another , AIR 2025 SC 173 wherein the Honourable Supreme Court of India held as under:

“18. A bare perusal of the FIR shows that the allegations made by respondent No.2 are vague and omnibus. Other than claiming that appellant No.1 harassed her and that appellant Nos.2 to 6 instigated him to do so, respondent No.2 has not provided any specific details or described any particular instance of harassment. She has also not mentioned the time, date, place, or manner in which the alleged harassment occurred. Therefore, the FIR lacks concrete and precise allegations.

24. Insofar as appellant Nos.2 to 6 are concerned, we find that they have no connection to the matter at hand and have been dragged into the web of crime without any rhyme or reason. A perusal of the FIR would indicate that no substantial and specific allegations have been made against appellant Nos.2 to 6 other than stating that they used to instigate appellant No.1 for demanding more dowry. It is also an admitted fact that they never resided with the couple namely appellant No.1 and respondent No.2 and their children. Appellant Nos.2 and 3