General and Omnibus Allegations Against In-Laws Not Sufficient for Prosecution under Section 498A IPC: Supreme Court Quashes Criminal Proceedings
Case Name: Dr. Sushil Kumar Purbey & Anr. v. State of Bihar & Ors.
Citation: 2026 INSC 212; Criminal Appeal arising out of SLP (Crl.) No. 3075 of 2024
Date of Judgment/Order: 09 March 2026
Bench: Hon’ble Mr. Justice Vikram Nath and Hon’ble Mr. Justice Sandeep Mehta
Held: The Supreme Court held that criminal proceedings against in-laws under Sections 498A, 341, 323 and 34 IPC and Sections 3 and 4 of the Dowry Prohibition Act cannot be sustained when the FIR contains only general and omnibus allegations without attributing any specific overt act to them. The Court held that where allegations against relatives of the husband are identical, vague and unsupported by specific details of conduct, the High Court must apply the same standard while considering quashing under Section 482 CrPC. Continuation of criminal proceedings in such circumstances would amount to abuse of the process of law.
Summary: The case arose from a matrimonial dispute following the marriage of the complainant with the son of the appellants in July 2019. The husband filed a divorce petition in March 2021 before the Family Court at Darbhanga. Subsequently, in March 2022, the complainant lodged an FIR alleging cruelty, dowry demand and physical assault by the husband, his parents (the present appellants) and his sister. The FIR alleged that the accused demanded a BMW car and subjected the complainant to harassment and cruelty and even attempted to strangulate her. During investigation, cognizance was taken by the Magistrate for offences under Sections 341, 323, 498A and 34 IPC and Sections 3 and 4 of the Dowry Prohibition Act. The appellants along with the sister-in-law approached the High Court under Section 482 CrPC seeking quashing of the proceedings. The High Court partly allowed the petition and quashed the proceedings only against the sister-in-law on the ground that the allegations against her were vague and omnibus, but refused to grant the same relief to the parents-in-law. The appellants challenged this distinction before the Supreme Court. The Court examined the FIR and found that the allegations against the sister-in-law and the appellants were materially identical and did not attribute any specific overt acts, dates or instances of misconduct to the parents-in-law. The Court observed that the only additional allegation was that the parents-in-law would quarrel with the complainant, which by itself did not constitute the alleged offences. The Court also noted that the criminal complaint was filed nearly one year after the husband instituted divorce proceedings, lending support to the contention that the FIR may have been a counter-blast to the matrimonial litigation.
Decision: The Supreme Court allowed the appeal, set aside the High Court’s order to the extent it refused to quash the criminal proceedings against the parents-in-law, and quashed all proceedings arising from the FIR insofar as the appellants were concerned, while clarifying that the criminal proceedings against the husband would continue in accordance with law.