Mr. State counsel, the FIR states that 'the husband and in-laws started abusing me.' Is that a specific allegation against each accused? How is this different from an omnibus allegation?

My Lord, the FIR is not required to be an encyclopaedia. It is a preliminary document that sets the criminal law in motion. The complainant has stated that all the accused, including the appellants, were involved in the harassment. The fact that they are collectively named does not make the allegation omnibus. In matrimonial disputes, it is often difficult to recount every specific incident on every specific date. The complainant will lead evidence during trial to establish the role of each accused. At the quashing stage, the Court should not insist on minute particulars. If the FIR discloses the ingredients of an offence, it should be allowed to proceed.

The divorce petition filed by the complainant contains detailed allegations against the husband but not against the appellants. Why should this not be considered?

My Lord, the divorce petition was filed for a different purpose — to seek dissolution of marriage. The allegations in the divorce petition are directed at the conduct of the husband because that is the legal requirement for divorce. The fact that the complainant did not repeat every allegation against every relative in the divorce petition does not mean that those allegations are false. The criminal proceedings are independent. The complainant can lead evidence against the appellants during the criminal trial, even if the divorce petition did not mention them in detail. The two proceedings have different standards of proof and different purposes.

The complainant travelled with the appellant Arti Mehta on Raksha Bandhan. Is that consistent with allegations of persistent harassment?

My Lord, victims of domestic violence often continue to interact with their abusers due to family pressures, societal expectations, or the desire to maintain superficial normalcy. Travelling with someone on a festival day does not mean that the allegations of harassment are false. The complainant may have been compelled to travel with her sister-in-law. The Court should not draw an adverse inference from such a circumstance. This is a matter for trial.

The brother-in-law Vikram Dhakad allegedly told the complainant to 'bring money from your maternal home as per our demand and either stay in Sheopur or stay in your maternal home.' Does this constitute a demand for dowry under Section 4 of the Dowry Prohibition Act?

My Lord, the Dowry Prohibition Act prohibits demand for dowry, directly or indirectly. The alleged statement is a demand for money as a condition for the complainant to continue staying in the matrimonial home. This falls within the ambit of dowry demand. Whether the statement was actually made and whether it constituted a dowry demand are questions of fact to be determined at trial. At the quashing stage, the Court must assume the allegations to be true and see whether they disclose an offence. Clearly, they do.

For RespondentCriminal Premium

Allegations Are Specific and Disclose Offences — (2026) INSC 533

The FIR and DV complaint contain specific allegations that the appellants demanded dowry, subjected the complainant to cruelty, and harassed her.

Arti Mehta v. State of Madhya Pradesh — (2026) INSC 533

Core Argument

The FIR and DV complaint contain specific allegations that the appellants demanded dowry, subjected the complainant to cruelty, and harassed her. The proceedings are at a nascent stage, and the truth of the allegations can only be tested at trial. The High Court correctly declined to exercise its inherent powers under Section 482 CrPC.

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