The court emphasized that vague allegations in matrimonial disputes can lead to misuse of legal provisions like Section 498A IPC, necessitating clear prima facie evidence for proceedings against family members.

ORDER:

This Criminal Petition is filed by the petitioners-accused Nos.2 and 3 seeking to quash the proceedings in FIR No.22 of 2025 on the file of the Kaghaznagar Town Police Station, Kumarambheem Asifabad District, for the offences under Sections 4 98-A IPC and 3 and 4 of the Dowry Prohibition Act (for short ‘DP Act’).

2. Heard Sri Mohammad Naseer Pasha, learned counsel for the petitioners and Sri Jithender Rao Veeramalla, learned Additional Public Prosecutor for the respondent No.1-State.

3. Learned counsel for the petitioners submitted that the petitioners are the parents-in-law of the de facto complainant ant that they never resided with the de facto complainant and never harassed her. He further submitted that they are residing in Riyad at Saudi Arabia and that there are no specific allegations against them and hence, prayed to quash the proceedings against the petitioners.

4. Learned Additional Public Prosecutor has submitted that during her stay of one month at her in-laws house, her in-laws harassed her and snatched away her cell phone and did not allow her to talk with her parents.

5. Perused the record.

6. The record discloses that the de facto complainant went along with her husband to Qatar after marriage and after two months of her stay, she was sent back to India and on arriving in India, she went to her in-laws house and stayed there for about a month. The allegation leveled against the petitioners is that they harassed her and they have not allowed her to talk to her parents over cell phone. This is the only averment against the petitioners herein. The allegations of harassment mostly refer to her husband-accused No.1. The specific allegation against the petitioners is that they have not allowed her to talk to her parents on cell phone. But for this, all the other allegations referred to the harassment made by her husband-accused No.1. Admittedly, the petitioners herein are residents of Riyad. Even assuming that she had stayed for a month with the in-laws, there are no specific incidents of harassment except the bald statement that they have not allowed her to talk to her parents. In Digambar v. State of Maharashtra , [2024 LawSuit (SC) 1196], it was alleged that the parents used to instigate their son (husband of the complainant)

against the complainant therein, the Apex Court has discussed the decision laid down in Dara Laxminarayana v. State of Telangana [2024 INSC 953] and also State of Haryana v. Bhajanlal [1992 Supp (1) SCC 335] and held as follows:

“The inclusion of Section 498A of the IPC by way of an amendment was intended to curb cruelty inflicted on a woman by her husband and his family, ensuring swift intervention by the State. However, in recent years, as there has been a notable rise in matrimonial disputes across the country, accompanied by growing discord and tension within the institution of marriage, consequently, there has been a growing tendency to misuse provisions like Section 498A of the IPC as a tool for unleashing personal vendetta against the husband and his family. Making vague and generalized allegations during matrimonial conflicts, if not scrutinized, will lead to the misuse of legal processes and an encouragement for use of arm twisting tactics by a wife and/or her family. Sometimes, recourse is taken to invoke Section 498A of the IPC against the husband and his family in order to seek compliance with the unreasonable demands of a wife. Consequently, this Court has, time and again, cautioned against prosecuting the husband and his family in the absence of a clear prima facie case against them.”

and has quashed the proceedings against the petitioners therein, who were parents-in-law of the de facto complainant therein.

7. Hence, in the light of the above s