Quashing of dowry harassment FIR for vague allegations against distant relatives upheld as abuse of process

General, omnibus allegations of dowry harassment against the husband's relatives, who lived in different cities, were found insufficient to sustain criminal proceedings where no specific role or overt act was attributed to each accused. The Court noted delay in approaching the police after leaving the matrimonial home, inconsistencies in the complainant's version, and material suggesting personal animosity, which weakened the prima facie case. Applying the settled quashing principles in Bhajan Lal, the SC held that continuation of the FIR and related proceedings would amount to abuse of process. The FIR and consequential criminal proceedings were quashed insofar as the appellants were concerned.

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Issues: Whether the FIR and consequential proceedings for alleged dowry harassment and cruelty against the appellants, who were relatives of the husband living in different cities and against whom only general allegations were made, were liable to be quashed under the inherent jurisdiction.

Analysis: The complaint and statement attributed broad allegations of dowry demand and harassment to the appellants, but the record showed that the complainant had left the matrimonial home in 2009 and approached the police only in 2013, shortly before the husband initiated divorce proceedings. The allegations against the mother-in-law and brothers-in-law were found to be general, omnibus, and unsupported by specific instances showing how each appellant participated in the alleged cruelty. The material also revealed inconsistencies, including the complainant's later statement that her jewellery remained with the husband and her admitted authorship of a complaint against one appellant, which indicated personal animosity. Applying the settled principles governing quashing and the illustrative categories in Bhajan Lal, the Court held that the allegations, even if taken at face value, did not make out a prima facie case and were so improbable that continuation of the criminal process would amount to abuse of process.

Conclusion: The FIR and consequential criminal proceedings were quashed insofar as the appellants were concerned.

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