$~88 * IN THEHIGH COURTOF DELHIAT NEW DELHI + CRL.M.C. 5066/2026 and CRL.M.A. 21263/2026 SUJAN SINGH SIKARWAR & ORS. .....Petitioners Through: Mr. Arimardhan Sharma and Ms.Nilanjani Tandon, Advocates. versus THE STATE OF NCT DELHI & ANR. .....Respondents Through: Ms. Kiran Bairwa, APP for State with SI Manju. CORAM: HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV O R D E R % 22.07.2026 CRL.M.A. 21264/2026 (for exemption) 1. Exemption allowed, subject to all just exceptions. 2. The application stands disposed of. CRL.M.C. 5066/2026 and CRL.M.A. 21263/2026 1. By way of the instant petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (corresponding to Section 482 of the Code of Criminal Procedure, 1973), the petitioners seek the quashing of FIR No. 371 dated 26.07.2023 qua offences under section 498A/406/34 of IPC and all consequential proceedings, including notice issued by the Court of JMFC Mahila Court-2 Patiala House District Courts, New Delhi, insofar as they relate to the present Petitioners. This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/07/2026 at 11:35:41 2. Petitioner no.1 is the brother-in-law, petitioner no.2 is the father-in- law and petitioner no.3 is the mother-in-law of the complainant/ respondent no.2 namely, Sadhana Singh Sikarwar.The marriage between complainant and the son of petitioner Nos. 2 and 3 was solemnised on 24.11.2008 according to Hindu rites and ceremonies. 3. Learned counsel appearing for the petitioners submits that the present FIR is a result of matrimonial discord between the complainant and her husband, and that the petitioners have been falsely implicated merely on account of their relationship with the husband. It is further submitted that the complaint, as originally lodged, did not contain any specific allegations against the present petitioners and that their names surfaced only subsequently during investigation. According to the petitioners, the allegations levelled against them are vague, omnibus and bereft of particulars regarding any overt act attributable to each of them. 4. Per contra, learned APP appearing for the State, opposes the petition and submits that during the course of investigation, the statement of the complainant was recorded wherein she specifically attributed acts of cruelty to the present petitioners. It is submitted that the material collected during investigation prima facie discloses their active participation in the commission of the alleged offences. 5. I have heard the submissions from the learned counsels and have perused the material on record. 6. A bare perusal of the facts of the case would indicate that an FIR was lodged against only the husband of the complainant, however, during the course of investigation, the statement of the complainant was recorded, which has also made allegations against the petitioners. It has come on This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/07/2026 at 11:35:41 record that the brother-in-law, father-in-law and mother-in-law have treated the complainant with cruelty. They all were assisting the complainant’s husband and were treating the complainant as their maid, subjecting her to cruelty as punishable under Section 498A, IPC. It has also been brought to the Court’s notice thatthey even restrained the complainant from lodging the complaint. 7. It is well settled that while exercising its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, the High Court cannot undertake a meticulous appreciation of the evidence or conduct what would amount to a mini-trial, as observed by the Supreme Court in CBI v. Aryan Singh.1It has been consistently held that at the stage of considering a petition for quashing, the Court is only required to examine whether sufficient prima facie material exists to proceed against the accused. 8. 8. At this stage, this Court is only required to ascertain whether the allegations contained in the FIR, read with the material collected during investigation, disclose the commission of cognizable offences and justify continuation of the criminal proceedings. As noticed hereinabove, the complainant in her statement during the investigation has attributed specific acts of cruelty and harassment to the present petitioners. The Investigating Agency, upon consideration of the material collected during investigation, has found sufficient grounds against them. 9. Bearing in mind the material which has been shown by the Investigating Officer through counsel, this Court is satisfied that there exists prima facie material against the petitioners to be summoned, therefore, the FIR in question cannot be quashed qua the present petitioners. 1(2023) 18 SCC 399 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/07/2026 at 11:35:41 10. Petitioners shall be at liberty to raise all their pleas during the course of trial. If they do so, let their objections be dealt with in accordance with law. 11. With the aforesaid observations, the instant petition stands dismissed. 12. All rights and contentions on merits are left open. PURUSHAINDRA KUMAR KAURAV, J JULY 22, 2026 Nc This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/07/2026 at 11:35:41