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2026 DAILYLAW 30374 (CHH)

VIKAS PANDEY v. STATE OF CHHATTISGARH

CRMP/3852/2025 · 2026-07-30

Shri Ravindra Kumar Agrawal

body2026

Judgment text

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1 CGHC010524162025 2026:CGHC:33150-DB NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR CRMP No. 3852 of 2025 1. Vikas Pandey S/o Shri Keshav Prasad Pandey Aged About 36 Years A/o 36 Years, R/o Mig 1/135, Sardar Vallabh Bai Patel Colony, Jamnipali, P.S. Darri, Tahsil Katghora, Distt. Korba, Chhattisgarh. 2. Annapurna Pandey W/o Shri Keshav Prasad Pandey Aged About 62 Years R/o Mig 1/35, Sardar Vallabh Bhai Patel Colony, Jamnipali, P.S. Darri, Tahsil Katghora, Distt. Korba, Chhattisgarh. 3. Keshav Prasad Pandey S/o Lt. Hemlal Pandey Aged About 67 Years R/o Mig 1/135, Sardar Vallabh Bhai Patel Colony, Jamnipali, P.S. Darri, Tehsil Katghora, Distt. Korba, Chhattisgarh. 4. Swati Tiwari W/o Shri Manoj Tiwari Aged About 35 Years R/o H. No. A/29, Rama Velley, Bodri, Bilaspur, Distt. Bilaspur, Chhattisgarh. 5. Shri Manoj Tiwari S/o Shri Manmohan Prasad Tiwari Aged About 43 Years R/o H. No. A/29, Rama Velley, Bodri, Bilaspur, Distt. Bilaspur, Chhattisgarh. ... Petitioner(s) versus BRIJMOHAN MORLE Digitally signed by BRIJMOHAN MORLE Date: 2026.08.01 13:06:05 +0530 2 1. State of Chhattisgarh Through Station House Officer, Police Chowki Naila, P.S. Janjgir, Distt. Janjgir Champa, Chhattisgarh. 2. Nidhi Pandey W/o Vikas Pandey Aged About 30 Years Presently R/o At Village Sarkhon, Ward No. 01, Chowki Naila, Distt. Janjgir Champa, Chhattisgarh. (Complainant) ...Respondent(s) (Cause-title taken from Case Information System) For Petitioners : Mr. Anit Tiwari, Advocate. For Respondent/State : Ms. Anusha Naik, Deputy Government Advocate. For Respondent No. 2 : Mr. Shivendu Pandya, Advocate. Hon'ble Shri Ramesh Sinha, Chief Justice Hon'ble Shri Ravindra Kumar Agrawal , Judge Order on Board Per Ramesh Sinha , Chief Justice 31 .07.2026 1. Heard Mr. Anit Tiwari, learned counsel for the petitioners. Also heard Mr. Anusha Naik, learned Deputy Government Advocate, appearing for the State/respondent No. 1 and Mr. Shivendu Pandya, learned counsel, appearing for respondent No. 2. 2. The present petition has been filed by the petitioners with the following prayers: “1. This Hon’ble Court may kindly be pleased to quash the impugned FIR No. 41 of 2025 dated 15.01.2025 3 registered at Police Station Janjgir (Police Chowki- Naila), District Janjgir-Champa (C.G.) under Section 498-A, 34 of IPC, lodged against the present petitioners, in the interest of justice. 2. This Hon’ble Court may kindly be pleased to quash the impugned charge-sheet No. 300 of 2025 dated 19.05.2025 filed on 10.06.2025 before learned Chief Judicial Magistrate, Janjgir, District Janjgir-Champa (C.G.) under Section 498-A, 34 of IPC against the present petitioners, in the interest of justice. 3. This Hon’ble Court may kindly be pleased to quash the subsequent criminal proceedings including impugned order of taking cognizance dated 10.06.2025 by learned Chief Judicial Magistrate, Janjgir, District Janjgir-Champa (C.G.) under Section 498-A, 34 of IPC in Criminal Case No. 1146 of 2025, in the interest of justice. 4. This Hon’ble Court may kindly be pleased to quash the impugned charges framed under Section 498-A, 34 of IPC on 04.09.2025 against the petitioners and order dated 04.09.2025 of framing of above charges passed by learned CJM, Janjgir, District Janjgir- Champa (C.G.) in Criminal Case No. 1146 of 2025, in the interest of justice. 5. This Hon’ble Court may be pleased to give such other relief(s) as this Hon’ble Court deems fit, in the interest of justice.” 3. Considering the fact that the dispute between the parties is purely matrimonial in nature, this Court, by order dated 22.07.2026, referred the matter to the Mediation Centre with a direction to petitioner 4 No.1/husband to deposit a sum of Rs. 1,00,000/-, which was directed to be released in favour of respondent No. 2/wife upon her appearance before the Mediation Centre. In compliance with the said order, petitioner No. 1/husband deposited the aforesaid amount, which was thereafter released to respondent No. 2/complainant upon her appearance. However, as per the report dated 28.07.2026 submitted by the Mediation Centre, the mediation proceedings could not culminate in an amicable settlement between the parties. Since the mediation proceedings failed, and with the consent of learned counsel appearing for the parties, the petition was heard finally. 4. Learned counsel for the petitioners submits that the present petition has been preferred seeking quashment of the impugned FIR, charge-sheet and the consequential criminal proceedings initiated against the petitioners in connection with Crime No. 41/2025 registered on 15.01.2025 at Police Station Janjgir (Police Chowki Naila), District Janjgir-Champa, for the offences punishable under Sections 498-A and 34 of the IPC. It is submitted that after completion of investigation, charge-sheet No. 300/2025 dated 19.05.2025 was filed on 10.06.2025 before the learned Chief Judicial Magistrate, Janjgir, upon which cognizance was taken on the same day and Criminal Case No.1146/2025 came to be registered. Thereafter, by order dated 04.09.2025, charges under Sections 498-A and 34 of the IPC have also been framed against the petitioners. 5. It is contended by the learned counsel for the petitioners that the 5 marriage between petitioner No.1, Vikas Pandey, and respondent No.2, Nidhi Pandey, was solemnized on 26.04.2024 at Janjgir. According to the prosecution, after a few days of marriage, the petitioners started harassing respondent No.2 on account of an alleged demand of dowry of Rs.5,00,000/-. It is further alleged that petitioner No.1 left respondent No.2 at her parental home on 04.06.2024, whereafter meetings for reconciliation were convened between the families, including one held at Hariyali Heritage, Janjgir, but no settlement could be arrived at. It is also alleged that on 23.07.2024 petitioner No.2 called respondent No.2 and her mother to Sarwamangla Temple, Korba, pursuant to which respondent No.2 returned to her matrimonial home on 31.07.2024 and stayed there for about twenty days, during which period she was allegedly subjected to cruelty and harassment. It is further alleged that petitioner No.2 attempted to physically assault her, compelling her to call the emergency service on Dial 112, following which she returned to her parental house. He further submitted that referring to the materials collected during investigation, learned counsel submits that the allegations are inherently improbable and are founded only on vague and omnibus assertions without attributing any specific overt act to any of the petitioners. According to him, even if the allegations contained in the FIR and the charge-sheet are accepted in their entirety, they do not disclose the essential ingredients constituting an offence under Section 498-A of the IPC. 6. It is further stated by the learned counsel, appearing for the petitioners that, in fact, after matrimonial disputes arose, the family 6 members of respondent No.2 had visited the petitioners' residence at Korba and threatened them with false criminal implication. Apprehending such action, petitioner Nos.1 and 2 had independently submitted written complaints before Police Station Darri as well as the Superintendent of Police, Korba. However, instead of taking appropriate action, the police merely issued notices under Section 155 Cr.P.C. This circumstance, according to learned counsel, clearly demonstrates that the petitioners had approached the authorities much prior to the lodging of the impugned FIR and that the present prosecution is nothing but a retaliatory measure. 7. It is also submitted that proceedings were initiated before the Parivar Paramarsh Kendra, Janjgir, in an attempt to amicably resolve the matrimonial dispute. However, despite sincere efforts on the part of the petitioners to restore the matrimonial relationship, the conciliation proceedings ultimately failed. Learned counsel submits that the very fact that the petitioners repeatedly participated in reconciliation efforts belies the allegation that they had been persistently harassing respondent No.2 for dowry. 8. Learned counsel further argues that respondent No.2 herself used to frequently stay at her parental home and had repeatedly expressed that she had married petitioner No.1 against her wishes and only under pressure from her family members. It is submitted that these circumstances have been completely ignored by the investigating agency while mechanically filing the charge-sheet. So far as petitioner 7 Nos.4 and 5 are concerned, it is submitted that petitioner No.4 is the sister-in-law of respondent No.2 and petitioner No.5 is her husband. Both of them are permanent residents of Bilaspur, whereas the matrimonial home of respondent No.2 is situated at Korba. They have been unnecessarily implicated despite residing separately and having no role whatsoever in the alleged matrimonial dispute. Learned counsel submits that there is absolutely no material collected during investigation to establish their involvement, and their implication is solely on account of their relationship with petitioner No.1. 9. It is further submitted that petitioner Nos.2 and 3 are elderly persons and subjecting them to the ordeal of a criminal trial on the basis of such vague and unsupported allegations would cause undue hardship and prejudice, particularly when no specific role has been assigned to them. Placing reliance upon the decision of the Supreme Court in Kahkashan Kausar @ Sonam v. State of Bihar1, learned counsel submits that the Hon’ble Supreme Court has repeatedly cautioned against the tendency of implicating all family members of the husband in matrimonial disputes by making general and omnibus allegations. It has been held that in the absence of specific allegations disclosing the individual role of each accused, continuation of criminal proceedings would amount to abuse of the process of law. 10. Reliance has also been placed upon K. Subba Rao and others v. State of Telangana represented by its Secretary, Department of 1 (2022) 6 SCC 599 8 Home and Others2, reported in (2018) 14 SCC 452 to contend that criminal courts must exercise greater caution while proceeding against the relatives of the husband in matrimonial disputes and that distant relatives cannot be compelled to face criminal prosecution merely on the basis of bald and generalized allegations unless specific instances demonstrating their active involvement are disclosed. 11. Learned counsel has further placed reliance upon State of Haryana & Others v. Bhajan Lal & Others3 and submits that the present case squarely falls within the categories enumerated therein warranting exercise of the inherent jurisdiction of this Court, inasmuch as the allegations are manifestly attended with mala fides and the criminal proceedings have been initiated only with an ulterior motive to harass the petitioners. Reliance has also been placed on the decision of this Court in Manoj Singh and Others v. State of Chhattisgarh and Another4 to contend that where the allegations against the relatives of the husband are general, omnibus and unsupported by any specific material, continuation of criminal proceedings would amount to abuse of the process of the Court and the same deserve to be quashed. 12. On the aforesaid premises, it is submitted that the impugned FIR, the consequential charge-sheet, the order taking cognizance, the order framing charge and all further criminal proceedings are nothing but an abuse of the process of law. It is, therefore, prayed that this Court, in exercise of its inherent jurisdiction, may be pleased to quash the entire 2 (2018) 14 SCC 452 3 1992 Supp (1) SCC 335 4 CRMP No. 2637 of 2019 9 criminal proceedings against the petitioners. 13. Per contra, learned Deputy Government Advocate appearing for the State/respondent No.1 opposed the petition and supported the impugned FIR, charge-sheet and the consequential criminal proceedings. It is submitted that, upon receipt of the complaint lodged by respondent No.2, the matter was duly investigated and, during the course of investigation, the statements of the complainant as well as other witnesses were recorded under Section 161 of the Code of Criminal Procedure. On the basis of the material collected during investigation, the Investigating Officer found sufficient grounds to submit the charge-sheet against the petitioners for the offences punishable under Sections 498-A and 34 of the IPC. It is further submitted that the learned Chief Judicial Magistrate, upon due consideration of the police report and the accompanying documents, has rightly taken cognizance of the offences and thereafter framed charges against the petitioners after being satisfied that a prima facie case exists against them. Learned State counsel would submit that the allegations made by the complainant disclose the commission of cognizable offences and the defence sought to be raised by the petitioners involves disputed questions of fact, which cannot be examined while exercising the inherent jurisdiction of this Court under Section 528 of the Bharatiya Nagarik Surakasha Sanhita, 2023 (for short, ‘BNSS’). It is thus submitted that no case for interference is made out and the present petition deserves to be dismissed. 10 14. Learned counsel appearing for respondent No.2 also vehemently opposed the petition and adopted the submissions advanced on behalf of the State. It is submitted that respondent No.2 was subjected to continuous physical and mental cruelty soon after the marriage on account of unlawful demand of dowry and that the allegations made in the FIR are duly supported by the statements recorded during investigation. It is contended that merely because the petitioners dispute the allegations, the criminal proceedings cannot be quashed at the threshold. According to learned counsel, the truthfulness or otherwise of the allegations can only be tested during the course of trial on the basis of evidence led by the parties and this Court, while exercising its inherent jurisdiction, ought not to undertake a meticulous appreciation of the evidence collected during investigation. It is further submitted that the FIR and the charge-sheet disclose a prima facie case against the petitioners and, therefore, no interference is warranted. On these grounds, it is prayed that the present petition be dismissed. 15. We have heard learned counsel for the parties and considered their rival submissions made hereinabove and also went through the records with utmost circumspection. 16. The allegations contained in the FIR, even if accepted in their entirety, disclose a matrimonial dispute which has been given a criminal colour. The complaint primarily contains general and omnibus allegations of cruelty, harassment and dowry demand without specifying the date, time or manner in which the alleged acts were committed by 11 each of the petitioners. Except for broad and sweeping assertions, there is no specific attribution of any overt act to any of the petitioners so as to prima facie constitute the ingredients of the offences alleged. The investigation has also culminated in filing of the charge-sheet without collecting any independent material to substantiate the allegations beyond the statements of interested witnesses. The continuation of criminal proceedings in such circumstances would amount to permitting the criminal process to be used as a weapon of harassment rather than for securing the ends of justice. 17. In the matter of Geeta Mehrotra and another v. State of Uttar Pradesh and another5, the Honb’ble Supreme Court has held that casual reference to the family member of the husband in FIR as co- accused particularly when there is no specific allegation and complaint did not disclose their active involvement. It was held that cognizance of matter against them for offence under Sections 498-A, 323, 504 and 506 of the IPC would not be justified as cognizance would result in abuse of judicial process. 18. In the matter of K. Subba Rao (supra) the Hon’ble Supreme Court delineated the duty of the criminal Courts while proceeding against relatives of victim's husband and held that the Court should be careful in proceeding against distant relatives in crime pertaining to matrimonial disputes and dowry deaths and further held that relatives of husband should not be roped in on the basis of omnibus allegations, unless specific instances of their involvement in offences are made out. 5 (2012) 10 SCC 741 12 19. In the matter of Rashmi Chopra v. State of Uttar Pradesh and Another6, it has been held by the Supreme Court relying upon the principle of law laid down in Bhajan Lal (supra) that criminal proceedings can be allowed to proceed only when a prima facie offence is disclosed and further held that judicial process is a solemn proceeding which cannot be allowed to be converted into an instrument of oppression or harassment and the High Court should not hesitate in exercising the jurisdiction to quash the proceedings if the proceedings deserve to be quashed in line of parameters laid down by the Supreme Court in Bhajan Lal (supra) and further held that in absence of specific allegation regarding anyone of the accused except common and general allegations against everyone, no offence under Section 498A IPC is made out and quashed the charges for offence under Section 498A of the IPC being covered by category seven as enumerated in Bhajan Lal (supra) by holding as under:- “24. Coming back to the allegations in the complaint pertaining to Section 498A and Section 3/4 of D.P. Act. A perusal of the complaint indicates that the allegations against the appellants for offence under Section 498A and Section 3/4 of D.P. Act are general and sweeping. No specific incident dates or details of any incident has been mentioned in the complaint. The complaint having been filed after proceeding for divorce was initiated by Nayan Chopra in State of Michigan, where Vanshika participated and divorce was ultimately granted. A few months after filing of the divorce petition, the complaint has been filed in 6 2019 SCC OnLine SC 620 13 the Court of C.J.M., Gautam Budh Nagar with the allegations as noticed above. The sequence of the events and facts and circumstances of the case leads us to conclude that the complaint under Section 498A and Section 3/4 of D.P. Act have been filed as counter blast to divorce petition proceeding in State of Michigan by Nayan Chopra. 25. There being no specific allegation regarding any one of the applicants except common general allegation against everyone i.e. “they started harassing the daughter of the applicant demanding additional dowry of one crore” and the fact that all relatives of the husband, namely, father, mother, brother, mother’s sister and husband of mother’s sister have been roped in clearly indicate that application under Section 156(3) Cr.P.C. was filed with a view to harass the applicants..…” 20. The Hon’ble Apex Court, in Payal Sharma v. State of Punjab & Another {Cr.A. No. 4773/2024, decided on 26.11.2024} had, relying on the decision in Geeta Mehrotra (supra), Kahkashan Kausar @ Sonam & Others v. State of Bihar & Others {(2022) 6 SCC 599}, Bhajan Lal (supra), and Umesh Kumar v. State of Andhra Pradesh & Another {(2013) 10 SCC 591}, had quashed the FIR and the consequential proceedings emanating therefrom. 21. Very recently, the Hon’ble Apex Court, in Dara Lakshmi Narayan & Others v. State of Telangana & Another {Cr.A. No. 5199 of 2024, decided on 10.12.2024}, has observed as under: “25. A mere reference to the names of family 14 members in a criminal case arising out of a matrimonial dispute, without specific allegations indicating their active involvement should be nipped in the bud. It is a well-recognised fact, borne out of judicial experience, that there is often a tendency to implicate all the members of the husband’s family when domestic disputes arise out of a matrimonial discord. Such generalised and sweeping accusations unsupported by concrete evidence or particularised allegations cannot form the basis for criminal prosecution. Courts must exercise caution in such cases to prevent misuse of legal provisions and the legal process and avoid unnecessary harassment of innocent family members. In the present case, appellant Nos.2 to 6, who are the members of the family of appellant No.1 have been living in different cities and have not resided in the matrimonial house of appellant No.1 and respondent No.2 herein. Hence, they cannot be dragged into criminal prosecution and the same would be an abuse of the process of the law in the absence of specific allegations made against each of them. 26. In fact, in the instant case, the first appellant and his wife i.e. the second respondent herein resided at Jollarpeta, Tamil Nadu where he was working in Southern Railways. They were married in the year 2015 and soon thereafter in the years 2016 and 2017, the second respondent gave birth to two children. Therefore, it cannot be believed that there was any harassment for dowry during the said period or that there was any matrimonial discord. Further, the second respondent in response to the missing complaint filed by the first appellant herein on 15 05.10.2021 addressed a letter dated 11.11.2021 to the Deputy Superintendent of Police, Thirupathur Sub Division requesting for closure of the said complaint as she had stated that she had left the matrimonial home on her own accord owing to a quarrel with the appellant No.1 because of one Govindan with whom the second respondent was in contact over telephone for a period of ten days. She had also admitted that she would not repeat such acts in future. In the above conspectus of facts, we find that the allegations of the second respondent against the appellants herein are too far-fetched and are not believable. 27. xxx xxx xxx 28. The inclusion of Section 498A of the IPC by way of an amendment was intended to curb cruelty inflicted on a woman by her husband and his family, ensuring swift intervention by the State. However, in recent years, as there have been a notable rise in matrimonial disputes across the country, accompanied by growing discord and tension within the institution of marriage, consequently, there has been a growing tendency to misuse provisions like Section 498A of the IPC as a tool for unleashing personal vendetta against the husband and his family by a wife. Making vague and generalised allegations during matrimonial conflicts, if not scrutinized, will lead to the misuse of legal processes and an encouragement for use of arm twisting tactics by a wife and/or her family. Sometimes, recourse is taken to invoke Section 498A of the IPC against the husband and his family in order to seek compliance 16 with the unreasonable demands of a wife. Consequently, this Court has, time and again, cautioned against prosecuting the husband and his family in the absence of a clear prima facie case against them. 29. We are not, for a moment, stating that any woman who has suffered cruelty in terms of what has been contemplated under Section 498A of the IPC should remain silent and forbear herself from making a complaint or initiating any criminal proceeding. That is not the intention of our aforesaid observations but we should not encourage a case like as in the present one, where as a counterblast to the petition for dissolution of marriage sought by the first appellant-husband of the second respondent herein, a complaint under Section 498A of the IPC is lodged by the latter. In fact, the insertion of the said provision is meant mainly for the protection of a woman who is subjected to cruelty in the matrimonial home primarily due to an unlawful demand for any property or valuable security in the form of dowry. However, sometimes it is misused as in the present case. 30. In the above context, this Court in G.V. Rao vs. L.H.V. Prasad, (2000) 3 SCC 693 observed as follows: “12. There has been an outburst of matrimonial disputes in recent times. Marriage is a sacred ceremony, the main purpose of which is to enable the young couple to settle down in life and live peacefully. But little matrimonial skirmishes suddenly erupt which often assume 17 serious proportions resulting in commission of heinous crimes in which elders of the family are also involved with the result that those who could have counselled and brought about rapprochement are rendered helpless on their being arrayed as accused in the criminal case. There are many other reasons which need not be mentioned here for not encouraging matrimonial litigation so that the parties may ponder over their defaults and terminate their disputes amicably by mutual agreement instead of fighting it out in a court of law where it takes years and years to conclude and in that process the parties lose their “young” days in chasing their “cases” in different courts.” 31. Further, this Court in Preeti Gupta vs. State of Jharkhand (2010) 7 SCC 667 held that the courts have to be extremely careful and cautious in dealing with these complaints and must take pragmatic realities into consideration while dealing with matrimonial cases. The allegations of harassment by the husband’s close relatives who had been living in different cities and never visited or rarely visited the place where the complainant resided would have an entirely different complexion. The allegations of the complainant are required to be scrutinized with great care and circumspection. 32. We, therefore, are of the opinion that the impugned FIR No.82 of 2022 filed by respondent No.2 was initiated with ulterior motives to settle personal scores and grudges against appellant No.1 and his family members i.e., appellant Nos.2 to 6 18 herein. Hence, the present case at hand falls within category (7) of illustrative parameters highlighted in Bhajan Lal. Therefore, the High Court, in the present case, erred in not exercising the powers available to it under Section 482 CrPC and thereby failed to prevent abuse of the Court’s process by continuing the criminal prosecution against the appellants.” Observing the aforesaid, the Hon’ble Apex Court quashed the FIR, the charge-sheet and the consequential criminal proceedings pending before the learned trial Court. 22. Reverting to the facts of the present case, this Court has carefully examined the allegations contained in the FIR, the statements recorded during investigation and the material accompanying the charge-sheet. A plain reading of the FIR would show that, except making broad allegations that the petitioners demanded dowry and subjected respondent No.2 to cruelty, no specific date, time, place or particular incident has been attributed to any of the petitioners individually. The allegations are substantially collective in nature and all the petitioners have been implicated by making sweeping assertions without disclosing the distinct role allegedly played by each of them. Even the statements recorded during investigation do not substantially improve the prosecution case so as to disclose the individual involvement of each petitioner. The investigation has merely reproduced the allegations of the complainant and her family members without collecting any independent material capable of lending assurance to the prosecution version. 19 23. It is also significant to note that petitioner Nos.4 and 5 are the sister-in-law of respondent No.2 and her husband, who are admittedly residing separately at Bilaspur, whereas the matrimonial home of respondent No.2 is situated at Korba. Except for the fact that they are related to petitioner No.1, there is no material collected during investigation indicating their participation in the alleged acts of cruelty or dowry demand. Their implication appears to be founded merely upon their relationship with the husband rather than upon any specific allegation demonstrating their active involvement. The Hon'ble Supreme Court has consistently deprecated such tendency of arraying every member of the husband's family as an accused in matrimonial disputes without there being concrete allegations against each of them. 24. This Court also cannot lose sight of the fact that the record itself reflects that efforts for reconciliation were made between the parties on more than one occasion and proceedings were also undertaken before the Parivar Paramarsh Kendra, though the same ultimately failed. The petitioners had also lodged complaints before the police authorities alleging that they had been threatened with false implication. While this Court refrains from expressing any opinion on the correctness of those complaints, the existence of such circumstances indicates that serious matrimonial discord had already arisen between the parties much prior to the lodging of the impugned FIR. In such a situation, the Court is required to examine the allegations with greater care so as to ensure that criminal law is not invoked as an instrument to settle matrimonial scores. 20 25. The inherent jurisdiction of this Court is undoubtedly to be exercised sparingly and with circumspection. At the same time, where the allegations, even if taken at their face value, fail to disclose the essential ingredients of the offences alleged or where continuation of the criminal proceedings would amount to abuse of the process of the Court, this Court would be justified in exercising its inherent powers to secure the ends of justice. The principles governing such exercise have repeatedly been explained by the Hon'ble Supreme Court in Bhajan Lal (supra) and have consistently been reiterated in Geeta Mehrotra (supra), Kahkashan Kausar (supra), Rashmi Chopra (supra), Payal Sharma (supra) and, most recently, in Dara Lakshmi Narayan (supra). 26. In the considered opinion of this Court, the present case squarely falls within the parameters laid down in the aforesaid decisions. Permitting the criminal prosecution to continue on the basis of such general and omnibus allegations, unsupported by specific material demonstrating the individual role of each petitioner, would result in misuse of the criminal process and would compel the petitioners to undergo the rigours of a criminal trial despite the absence of a prima facie case. Criminal law cannot be permitted to become a means of exerting pressure in matrimonial disputes or of unnecessarily prosecuting every member of the husband's family merely because of their relationship with the husband. 27. Consequently, the present petition deserves to be and is accordingly allowed. FIR No.41/2025 dated 15.01.2025 registered at 21 Police Station Janjgir (Police Chowki-Naila), District Janjgir-Champa (C.G.) for the offences punishable under Sections 498-A and 34 of the IPC, the charge-sheet No.300/2025 dated 19.05.2025 filed on 10.06.2025, the order dated 10.06.2025 taking cognizance passed by the learned Chief Judicial Magistrate, Janjgir in Criminal Case No.1146/2025, the order dated 04.09.2025 framing charges against the petitioners and all consequential criminal proceedings arising therefrom are hereby quashed. 28. No order as to costs. Sd/- Sd/- (Ravindra Kumar Agrawal) (Ramesh Sinha) Judge Chief Justice Brijmohan