In a significant ruling, the Karnataka High Court has underscored that vague and general allegations of harassment by in-laws, without specific instances of misconduct, are insufficient grounds for criminal prosecution. The court quashed proceedings against a family from Kalaburagi, emphasizing the need for concrete evidence to prevent misuse of legal processes.
Court's Rationale for Quashing the FIR
Justice Sachin Shankar Magadum delivered the judgment on a petition filed by Abeda, her husband Mohammad Runkuddin Jumna, and five other family members. They had challenged an FIR registered at a women's police station and subsequent court proceedings initiated by their daughter-in-law, Tehseen Begum, in July 2023.
The judge observed that the mere assertion that in-laws "instigated" the husband or used abusive language, without detailing any specific incident, cannot form the foundation for a criminal case. Justice Magadum noted that forcing the petitioners to undergo a full trial based on such unsubstantiated claims would subject them to an unnecessary legal ordeal, amounting to an abuse of the judicial process.
Key Facts and Complainant's Own Admissions
After examining the complaint and records, Justice Magadum highlighted crucial points that weakened the prosecution's case. The complainant, Tehseen Begum, in her written complaint dated July 22, 2023, explicitly acknowledged that she lived separately with her husband, Nooruddin Jumna, following a family partition.
"The complainant explicitly acknowledges that there was a family partition, pursuant to which, a separate residential portion comprising three rooms was allotted. This itself indicates that the petitioners lived separately and did not share the common household with the complainant," the judge stated.
The petitioners argued that all allegations of neglect, discord, and harassment were directed solely at Nooruddin, with no specific accusations against them individually. The court agreed, finding the claims against the in-laws to be broad and lacking any particulars of date, time, place, or specific acts.
Underlying Cause of Marital Discord Identified
Justice Magadum also pointed to a critical detail in the complaint that explained the root of the marital problems. "The complaint also repeatedly refers to the prolonged stays of Nooruddin in the Gulf region, which appears to be the primary reason for the marital discord," the observation noted.
This factor further isolated the core issue between the husband and wife, distancing the other family members from direct culpability. The judgment reinforces the legal principle that criminal law requires precise allegations, especially when individuals are accused of aiding or abetting an offense.
Implications of the Judgment
This ruling serves as a crucial precedent, potentially curbing the trend of filing blanket criminal cases against entire families in marital disputes. It reiterates the judiciary's role in protecting citizens from frivolous and vexatious litigation that can cause immense social and financial strain.
By exercising its inherent power under Section 482 of the Code of Criminal Procedure (CrPC) to quash the proceedings, the High Court has sent a clear message: allegations must be specific and substantiated, particularly when they target extended family members who do not share a common household with the complainant.
The decision provides significant relief to the accused petitioners from Kalaburagi and sets a benchmark for evaluating similar cases where in-laws are implicated based on general and unspecific claims of instigation or harassment.
