A recent judgment by the Bombay High Court where Justice Bharati Dangre and Justice Manjusha Deshpande formed part of the bench, has quashed an FIR filed by her uncle's wife against Pragati Kapoor. From this case, she learns a very important legal principle related to the scope of cases that can be covered by the complaint brought under the Protection of Women from Domestic Violence Act, 2005.The Background of the Case The petitioner, Pragati Kapoor, had filed a plea before the Bombay High Court seeking the quashing of FIR lodged against her by her uncle's wife alleging domestic violence. Pragati is the niece of Manishchandra Kapoor and is accused of abetting her uncle to harass his wife. The case was filed under various sections of the Indian Penal Code, besides provisions of the Domestic Violence Act that include family members in its purview for actions of physical, emotional, and mental harassment. Key Arguments Counsels for Pragati Kapoor pleaded that the FIR filed against her was devoid of substance and hence legally not sustainable. She canvassed that neither did she live with this couple nor was she directly involved in their domestic affairs. The contention is that the Protection of Women from Domestic Violence Act applies only to direct participants in the domestic environment of the aggrieved woman. According to the petitioner, such a proceeding was an abuse because the FIR sought to extend the provisions relating to domestic violence to include the class of people who do not fall within the domestic setup. Her counsel claimed that such cases would have dealt only with those having a domestic relationship with one another, such as closely related family members living in the same house, rather than involving distant relatives like a niece. The observations of the Court and Judgement After hearing the arguments, the bench agreed with the defense that petitioner's inclusion in the FIR was not justified. The court observed that under the Protection of Women from Domestic Violence Act, a "domestic relationship" becomes a vital factor defining the boundary of those who could be implicated. Domestic relationship would relate to relationships where parties are living in a shared household and have family ties based on marriage, adoption, or blood relations. Justice Dangre and Justice Deshpande held that the niece, Pragati Kapoor, who neither stayed with the couple nor had any important affairs to do with them in their daily life, would not be bringable under the Domestic Violence Act. The court also observed that bringing relative or other legal more and more to the extent of the claim for domestic violence would become easy misuse of the laws.