1. This petition is filed under Section 482 of the Code of Criminal Procedure, 1973 (for short, “Cr.P.C.”), seeking quashment of the proceedings in C.C. No.958 of 2024 on the file of III Additional Civil Judge-cum-III Additional Judicial Magistrate of I Class, Hanumakonda District for the offences punishable under Sections 498-A and 506 of Indian Penal Code (for short, “IPC’’) and Sections 3 and 4 of Dowry Prohibition Act, 1961 (for short, “D.P. Act”). The petitioner is arrayed as accused No.4 herein.

2. Heard Mr. Karra VVSN Murthy, learned Counsel for the petitioner, and Mr. Mr. Syed Yasar Mamoon, learned Additional Public Prosecutor, representing the respondent-State and Mr. G. Manoj Goud, learned Counsel representing Mr. T. Basavaiah, learned Counsel for respondent No.2.

3.1. The prosecution case, in brief, is that the 2nd respondent/complainant married accused No.1 on 26.08.2021. It is alleged that, at the time of the marriage, at the demand of accused No.1, the complainant’s parents gave a sum of Rs.20 lakhs in cash and gold ornaments worth approximately Rs.5 lakhs to accused No.1 and his family members towards dowry. According to the complainant, the matrimonial relationship remained cordial only for about one month after the marriage. Thereafter, accused No.1 allegedly subjected her to physical and mental harassment by demanding additional dowry for the purchase of a plot and a car and subsequently demanded a further sum of Rs.20 lakhs for purchasing a house.

               3.2. It is further alleged that accused No.1 abused and insulted the complainant and threatened her with dire consequences if the additional dowry demands were not fulfilled. He also allegedly threatened to contract a second marriage, stating that he was not interested in continuing the matrimonial relationship. The complaint further alleges that the harassment and additional dowry demands were made by accused No.1 at the instigation of his mother, sister, and her husband, who is the petitioner herein/accused No.4. Although elders are stated to have intervened and made efforts to resolve the matrimonial dispute, the alleged harassment and demands are stated to have continued. Consequently, the complainant approached the police, pursuant to which a crime was registered. Upon completion of the investigation, the police filed a charge sheet, and the case was numbered as C.C. No.958 of 2024 and is pending trial.

4.1. Learned Counsel for the petitioner submits that the petitioner/accused No.4 had only a limited role in the matrimonial dispute between the complainant and accused No.1, namely, making efforts to bring about a settlement between them and coordinating with the elders for conducting panchayats. It is contended that the allegations levelled against the petitioner are general, vague, and omnibus in nature and that no specific overt act or particular instance of physical or mental harassment has been attributed to him.

               4.2. According to the petitioner, the material available on record does not disclose that he subjected the complainant to any cruelty or harassment so as to attract the ingredients of Section 498-A of the IPC. It is further contended that there is no specific or credible allegation that the petitioner threatened the complainant with injury to her person, reputation, or property so as to constitute an offence under Section 506 of the IPC. He further submits that there is no specific allegation of any demand for dowry by the petitioner, nor is there any allegation of any act committed by him in connection with the alleged dowry demand so as to attract the provisions of the Dowry Prohibition Act.

               4.3. It is further submitted that the petitioner is merely a relative by marriage, being the husband of the sister of accused No.1, and had no role in the matrimonial relationship between the complainant and her husband. According to the petitioner, mere relationship with the husband’s family, in the absence of specific allegations demonstrating his participation in the alleged harassment or dowry demands, would not constitute the offences alleged against him.

               4.4. Learned Counsel for the petitioner further contends that the petitioner has been unnecessarily and falsely implicated in the case despite his efforts to resolve the matrimonial dispute between the complainant and accused No.1. It is submitted that the petitioner’s involvement was confined to assisting in the settlement efforts and coordinating with the elders who intervened in the matter. It is therefore contended that continuation of the criminal proceedings against the petitioner, in the absence of specific and credible material indicating his involvement in the alleged offences, would amount to an abuse of the process of law. It is further argued that, even if the allegations contained in the FIR and the charge sheet are taken at their face value, they do not disclose the essential ingredients of the offences alleged against the petitioner. On these grounds, the petitioner seeks quashing of the proceedings insofar as they relate to him.

5.1. Per contra, the learned Counsel appearing for Respondent No.2/defacto-complainant would submit that the allegations levelled against the petitioner/accused No.4 are neither vague nor unsupported by material on record. It is contended that the allegations are specifically set out in the complaint and are corroborated by the statements of the complainant and the witnesses recorded during the course of investigation.

               5.2. It is submitted that the material collected during investigation discloses the marriage between the complainant and accused No.1, the payment of dowry at the time of marriage, and the subsequent demands for additional dowry. According to Respondent No.2, after the marriage, the complainant was subjected to physical and mental harassment in connection with demands for further amounts of money, including a demand for money for the purchase of a car.

               5.3. So far as the specific role attributed to accused No.4 is concerned, learned Counsel would submit that his involvement is not alleged merely on account of his relationship with accused No.1/husband. Rather, specific acts and circumstances have been attributed to him connecting him with the continuing dowry-related demands and harassment. It is alleged that, after the marriage, further amounts and a four-wheeler/car were demanded and that accused No.4 remained in regular communication with the other accused in relation to such financial demands and supported and encouraged their conduct.

               5.4. It is further submitted that, following the incident and the intervention of the panchayat/elders, accused No.1 contacted accused No.4 over the phone and, instead of supporting Respondent No.2, accused No.4 allegedly supported accused No.1 and participated in making allegations against Respondent No.2. According to learned Counsel, the circumstances relied upon against accused No.4 form a connected chain, comprising, (i) his alleged participation in the initial dowry demand; (ii) his alleged participation in the subsequent demand for Rs.10,00,000/- and the execution of the stamp-paper undertaking; (iii) his association with the subsequent financial and vehicle-related demands; (iv) his communications with the other accused; (v) his alleged knowledge of the financial transactions involving A-3; and (vi) his conduct subsequent to the balcony incident. It is therefore contended that the material against accused No.4 has to be considered cumulatively and that, at this stage, the allegations cannot be characterised as vague, omnibus or wholly unsupported by the material collected during investigation.

               5.5. The learned Additional Public Prosecutor would submit that specific allegations have been made against the petitioner/ accused No.4 regarding his participation in the initial dowry demand and the subsequent acts of harassment along with the other accused. It is contended that the statements of the complainant and other witnesses recorded during the course of investigation lend prima facie corroboration to the allegations concerning the dowry transaction, the subsequent demand for Rs.20,00,000/-, the alleged physical and mental harassment, abuse and threats, the alleged threat to kill the complainant, the threat of a second marriage, and the intervention of elders in an attempt to resolve the matrimonial dispute.

               5.6. The learned Additional Public Prosecutor would further submit that the investigation has resulted in the collection of prima facie material against all the accused, including the petitioner, and that, upon consideration of such material, the police filed the charge sheet for the offences alleged against them. It is further contended that the matters raised by the petitioner concerning the truthfulness of the allegations, the sufficiency and evidentiary value of the material collected during investigation, and the precise nature and extent of his participation are essentially matters of evidence. Such questions, according to the prosecution, are required to be examined during trial on the basis of the evidence that may be adduced before the competent Court and cannot, at this stage, be conclusively adjudicated upon in proceedings seeking quashing of the criminal case. On the aforesaid grounds, the learned Additional Public Prosecutor would oppose the criminal petition and seek its dismissal.

6. I have carefully considered the submissions and perused the material available on record.

7. While exercising jurisdiction under Section 482 of the Cr.P.C., this Court ordinarily does not undertake an appreciation of evidence or adjudicate upon the truthfulness or otherwise of the allegations. However, interference is warranted where the allegations made in the complaint/FIR and the material collected during the investigation, even if taken at their face value and accepted in their entirety, do not disclose the commission of the alleged offences by the accused. The principles laid down by the Hon’ble Supreme Court in State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335, continue to govern the jurisdiction, particularly while examining whether continuation of criminal proceedings would amount to an abuse of the process of law.

8. In the present case, insofar as the petitioner/accused No.4 is concerned, the prosecution alleges that, being the husband of the sister of accused No.1, he participated in the initial demand for dowry and in the subsequent matrimonial harassment of the complainant. However, on a careful consideration of the material placed before this Court, the allegations against the petitioner are found to be substantially general and omnibus in nature. The material does not attribute to him any distinct overt act, any specific demand for dowry, any particular threat, or any specific incident constituting physical or mental cruelty.

9. Although the statements of the prosecution witnesses support the general allegations relating to the demand for additional dowry, harassment, threats, and intervention by elders, the material collected during the investigation does not disclose any specific act or conduct individually attributable to the petitioner. The alleged participation of the petitioner in subsequent panchayat or settlement efforts, including the reference to a telephone call made by accused No.1, by itself does not constitute an act of cruelty or criminal intimidation on the part of the petitioner. The mere fact that the petitioner is related to accused No.1 cannot, in the absence of specific allegations and supporting material indicating his individual participation in the alleged offences, furnish a sufficient basis for continuing the criminal proceedings against him.

10. The essential requirement, particularly in a prosecution arising out of matrimonial discord, is that there must be specific allegations and supporting material connecting the particular accused with the acts constituting the alleged offences. Mere implication on account of the accused’s relationship with the husband or his family, without particulars demonstrating his individual involvement, would not by itself satisfy that requirement.

11. The Hon’ble Supreme Court has repeatedly cautioned against continuation of criminal proceedings against relatives of the husband in matrimonial cases where the allegations are general, vague, or omnibus and do not disclose specific instances of their individual involvement. In Geeta Mehrotra & Anr. v. State of U.P., (2012) 10 SCC 741; Kahkashan Kausar @ Sonam v. State of Bihar, (2022) 6 SCC 599; Abhishek v. State of Madhya Pradesh, 2023 INSC 779; and Dara Lakshmi Narayana v. State of Telangana, (2025) 3 SCC 735, the Hon’ble Supreme Court has emphasised the need for specific allegations and material demonstrating the individual participation of a relative before permitting such criminal proceedings to continue.

12. The same principle is applicable to the allegations under Sections 3 and 4 of the D.P. Act. The material must disclose the individual involvement of the petitioner in the alleged demand for dowry or in the transaction constituting the alleged offence. In the absence of any specific allegation that the petitioner himself demanded dowry or participated in the alleged dowry transaction, his mere relationship with the family of accused No.1 would not, by itself, be sufficient to sustain the prosecution under the said provisions.

13. Likewise, insofar as Section 506 of the IPC is concerned, the allegations relating to threats to kill the complainant and the threat of a second marriage, as summarised in the material placed before this Court, are principally attributed to accused No.1. There is no specific allegation of any particular act of criminal intimidation committed by the petitioner or of any threat made by him to the complainant. Consequently, the material, even when accepted at its face value, does not disclose the necessary ingredients of an offence under Section 506 of the IPC insofar as the petitioner is concerned.

14. The distinction between cases founded merely upon general and omnibus allegations and cases containing specific allegations concerning the individual participation of a particular accused has also been recognised by the Hon’ble Supreme Court in Krishnakant Kwivedy v. State of Chhattisgarh, 2025 INSC 958. The principle emerging from the said decisions is that while the Court should not conduct a detailed examination of the evidence at the stage of exercising jurisdiction under Section 482 of the Cr.P.C., criminal proceedings cannot be permitted to continue against an individual accused where the material, even if accepted in its entirety, does not disclose his specific involvement in the alleged offences.

15. This Court is conscious of the settled principle that, while exercising jurisdiction under Section 482 of the Cr.P.C., a mini-trial cannot be conducted and the credibility or reliability of prosecution witnesses cannot ordinarily be assessed. The present conclusion, however, is not founded upon an appreciation of the credibility of the witnesses or upon a determination of the truthfulness of the rival versions. It is founded upon the absence of specific allegations and supporting material disclosing the individual acts of the petitioner which would constitute the ingredients of the offences alleged against him. In other words, the question before this Court is not whether the allegations are ultimately true or whether the prosecution witnesses are worthy of belief. The limited question is whether, assuming the allegations contained in the charge sheet and the statements of the witnesses to be true in their entirety, they disclose the commission of the alleged offences by this particular accused. On that limited examination, this Court finds that the material against the petitioner does not travel beyond general allegations of his association or participation along with the other accused and does not disclose any specific overt act attributable to him.

16. Therefore, when the charge sheet and the statements of the witnesses are taken at their face value, the material placed before this Court does not disclose any specific act of the petitioner constituting cruelty, criminal intimidation, or participation in the alleged dowry demand or transaction. The case insofar as the petitioner is concerned, therefore, falls within the principles laid down by the Hon’ble Supreme Court in State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335; Geeta Mehrotra & Anr. v. State of U.P., (2012) 10 SCC 741; and Dara Lakshmi Narayana v. State of Telangana, (2025) 3 SCC 735.

17. In the considered view of this Court, continuation of the criminal proceedings against the petitioner/accused No.4, in the absence of specific and substantive material disclosing his individual involvement in the alleged offences, would amount to an abuse of the process of law. Accordingly, the proceedings in C.C. No.958 of 2024 are liable to be quashed insofar as the petitioner/accused No.4 alone is concerned.

18. It is made clear that the quashing of the proceedings against the petitioner shall not, in any manner, amount to an adjudication upon the truth or otherwise of the allegations against the remaining accused, nor shall it affect the prosecution against them. The proceedings against the remaining accused shall be permitted to continue in accordance with law and shall be decided by the competent Court independently, on the basis of the material and evidence available before it.

19. Accordingly, the Criminal Petition is allowed. Consequently the proceedings against the petitioners/Accused No.4 in C.C. No.958 of 2024 on the file of III Additional Civil Judge-cum-III Additional Judicial Magistrate of I Class, Hanumakonda District, are hereby quashed.

Pending miscellaneous applications, if any, shall stand closed.