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2026 Supreme(Online)(Kar) 1603

THE HIGH COURT OF KARNATAKA
M.NAGAPRASANNA, J
SMT. DHANALAKSHMAMMA W/O GANGADHARA GOWDA – Appellant
Versus
STATE OF KARNATAKA – Respondent
CRIMINAL PETITION NO. 1816 OF 2024



Advocates:
For the Appellants/Petitioners: SMT. KEERTHI REDDY
For the Respondents: SRI. B.N. JAGADEESHA, SRI. ANTONY IGNATIUS M.J.

Family members cannot be implicated in dowry-related offences without specific allegations; vague accusations may lead to misuse of legal provisions.

Headnote:(A) Indian Penal Code, 1860 - Sections 498A, 504, 506, 149 - Quashing of FIR - Petitioners, family members of accused, challenge registration of FIR under various IPC sections for cruelty and dowry demand - Court finds no prima facie ingredients of alleged offences against petitioners - Emphasis on need for specific allegations against family members in matrimonial disputes - Proceedings quashed due to absence of concrete evidence or overt acts by petitioners. (Paras 4, 8, 11, 14, 18)

Table of Content
1. overview of the case and parties involved. (Para 1 , 2)
2. arguments presented by both sides regarding the registration of the fir. (Para 3 , 4 , 5)
3. discussion on the vague and ambiguous nature of the allegations against petitioners. (Para 8 , 9 , 10)
4. court's reasoning based on prior judgments concerning family members. (Para 11 , 12)

ORAL ORDER

The petitioners - mother-in-law, father-in-law, brothers- in-law and sister-in-law stand before this Court calling in question registration of a crime in Crime No.36/2024 registered for offences punishable under Sections 498A , 504, 506 and 149 of the IPC .

2. Heard Smt. Keerthi Reddy, learned counsel appearing for the petitioners, Sri. B.N. Jagadeesha, learned counsel appearing for respondent No.1, Sri. Antony Ignatius M.J., learned counsel appearing for respondent No.2 and have perused the material on record.

3. Facts adumbrated are as follows: Respondent No.2-complainant gets married to the son of the first petitioner - accused No.1 on 02.03.2015. Accused No.1 is not before the Court. It transpires that after about 8 years of matrimonial life, the relationship flounders. On floundering of the relationship, there are several proceedings instituted by the wife against the husband and family members, or the husband against the wife, the complainant herein. The issue relates to a complaint being registered on 07.02.2024 by the wife for the aforesaid offences, which becomes a crime in Crime No.36/2024. After the registration of the crime, it transpires that several other proceedings are instituted, which are not relevant for consideration of the issue, in the subject lis. The registration of the crime, has driven these petitioners to the Court in the subject petition, on a contention that there are no allegations that would touch upon the ingredients of the afore- quoted offences.

4. Learned counsel, Smt. Keerthi Reddy, appearing for the petitioners, would vehemently contend that a perusal at the complaint even would not indicate any offence that can become the ingredients of Section 498A of the IPC or any other offence that is alleged in the crime so registered. She would take this Court through the documents appended to the petition prima facie to demonstrate that the parents are not residing with the couple and therefore, did not interfere in the affairs of the marriage between the complainant and accused No.1. She would seek to place reliance upon the judgment of the Apex Court in the case of RAJESH CHADDHA V. STATE OF UTTAR PRADESH , 2025 SCC OnLine SC 1094 to buttress her submission that dragging of the members of the family in a case under of the should not be entertained as the Apex Court has held so. She would seek quashment of the proceedings.

5. Learned counsel appearing for respondent No.2- complainant would however dispute the fact that the parents were not involved in the demand of dowry on the complainant and for the reason of such demand not being met, have meted out cruelty against the wife. He would also rely on the very complaint to contend that it is a matter of investigation in the least or a trial to be faced by these petitioners to come out clean and therefore, seeks dismissal of the petition.

6. Learned Addl.SPP, apart from toeing the lines of the learned counsel appearing for the second respondent, would submit that against the husband, charges have been framed and the evidence is on and the charge sheet is not filed against these petitioners, as there was an interim order operating in the case at hand and therefore, investigation should be permitted to be continued against these petitioners and the petitioners also should come out clean in a full blown trial, as the trial is on against the husband. He would seek dismissal of the petition.

7. I have given my anxious consideration to the respective submissions made by the learned counsel and have perused the material on record.

8. The facts noticed in its broad outline is not in dispute. The marriage

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