Ms. Mehta, the complainant has alleged that the mother-in-law, brother-in-law, and sister-in-law also demanded dowry and harassed her. Why should these allegations be ignored merely because they are not as detailed as those against the husband?

My Lord, the petitioners do not ask the Court to ignore the allegations. They ask the Court to examine whether the allegations, as they stand, disclose a prima facie case against each petitioner individually. The FIR states that 'the husband and in-laws started abusing me' — this is a collective assertion. It does not state which petitioner said what, on which date, or in what manner. The complainant had the opportunity to provide specific details in the FIR, the DV complaint, and the divorce petition. She provided specific details against the husband — dates, incidents, overt acts. Against the petitioners, she did not. The law requires specific allegations to set criminal law in motion. Generalised collective assertions are insufficient.

The High Court observed that the proceedings are at a nascent stage and that the truth of the allegations can be tested at trial. Why should this Court interfere at this stage?

My Lord, the stage of proceedings is not determinative. If the allegations, even on their face value, do not disclose an offence, the Court can and should interfere at any stage. In Anand Kumar Mohatta, this Court held that the power under Section 482 CrPC can be exercised even after charge-sheet is filed. Here, the allegations against the petitioners are so vague that no prudent person could conclude that they disclose commission of an offence. Forcing the petitioners to go through trial would be an abuse of process. The petitioners should not be made to suffer the ignominy of a criminal trial when there is no specific allegation against them.

The complainant has alleged that the brother-in-law Vikram Dhakad told her to bring money from her maternal home or leave. Is that not a specific allegation of dowry demand?

My Lord, even if that allegation is accepted, it does not constitute an offence under Section 4 of the Dowry Prohibition Act. The alleged statement was made in the context of advising the complainant where she should stay — either stay in Sheopur with her husband, or stay in her maternal home in Guna. The word 'demand' in the Dowry Prohibition Act requires a request for property or valuable security as a condition for marriage. Here, the marriage had already taken place. The alleged statement, even if true, does not amount to a dowry demand under the Act. Moreover, the complainant continued to stay in the matrimonial home and did not leave immediately after this alleged incident. The allegation is vague and does not constitute an offence.

The complainant's divorce petition was filed by her. The allegations in that petition are against the husband. That only shows that the complainant had serious grievances against the husband, not that the petitioners are innocent.

My Lord, the divorce petition is relevant because it shows that the complainant was capable of providing detailed, specific allegations when she wanted to. She provided specific dates, incidents, and overt acts against the husband. The fact that she did not provide similar specific allegations against the petitioners in the same petition indicates that the allegations against the petitioners are not based on specific facts but are merely an afterthought or a result of matrimonial acrimony. The petitioners are not asking for a finding of innocence; they are asking that the proceedings be quashed because the allegations, as they stand, do not make out a prima facie case against them. This is a legitimate request under Section 482 CrPC.

For PetitionerCriminal Premium

Omnibus Allegations Without Specific Overt Acts — (2026) INSC 533

The allegations against the appellants are generalised, omnibus, and lack any specific overt act, date, or individual attribution.

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

Core Argument

The allegations against the appellants are generalised, omnibus, and lack any specific overt act, date, or individual attribution. The complainant has not disclosed as to which appellant made what demand, on which occasion, or in what manner. The proceedings against them amount to abuse of process and deserve to be quashed.

Key Precedents

State of Haryana v. Bhajan Lal 1992 Supp (1) SCC 335 — Laid down categories where inherent power under Section 482 CrPC can be exercised to quash FIRs.
Anand Kumar Mohatta v. State (NCT of Delhi) (2019) 11 SCC 706 — Held that Section 482 CrPC power can be exercised even after filing of charge-sheet.

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