COURT’S DECISION
The Court exercised its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita and quashed the FIR registered for offences under Sections 498A/406/34 IPC, along with all consequential proceedings. The Court relied on the complete matrimonial settlement, the dissolution of marriage by a competent Family Court, the full payment of ₹5,00,000 settlement amount, and the absence of any coercion.
The Court reiterated that when matrimonial disputes are amicably resolved, criminal proceedings arising from the matrimonial discord should be brought to a quietus, as continuation of prosecution would amount to abuse of process.
FACTS
The case originated from a matrimonial dispute between two individuals whose marriage was solemnised in 2019 as per Muslim rites. A child was born out of the wedlock. Due to temperamental differences, the spouses began residing separately in the same year.
The complainant alleged that she was subjected to physical and mental cruelty on account of dowry demands. This led to registration of an FIR under Sections 498A/406/34 IPC at the concerned police station.
During the pendency of proceedings, both sides voluntarily agreed to resolve their disputes. They executed a written settlement agreement dated 16 December 2024 at the Counselling Cell of Saket District Courts. As per the settlement:
- The marriage was dissolved by a decree dated 26 August 2025.
- The complainant received a total settlement amount of ₹5,00,000 along with identified articles.
- Custody of the minor child was vested with the complainant, with the other party granted visitation rights.
During the High Court hearing, all petitioners except one appeared physically, and the remaining individual joined via video conferencing. The complainant was present, identified by counsel and the Investigating Officer, and confirmed the settlement.
ISSUES
- Whether the High Court should exercise inherent jurisdiction to quash the FIR in a matrimonial dispute after a lawful settlement.
- Whether continuation of criminal proceedings under Sections 498A/406/34 IPC would amount to abuse of process when the complainant raises no objection.
- Whether non-compoundable matrimonial offences can be quashed based on voluntary compromise.
- Whether the settlement was free from coercion, pressure or undue influence.
PETITIONER’S ARGUMENTS
The petitioners contended that the dispute was purely matrimonial in nature and had been fully resolved. They pointed to the written settlement, dissolution of marriage, and complete payment of settlement amount. They argued that the complainant had voluntarily confirmed the agreement before the Court and accepted all articles due to her.
It was submitted that continuation of prosecution after the termination of matrimonial relationship would lead to unnecessary harassment and defeat the object of amicable settlement frameworks recognized by courts. They relied on the complainant’s categorical statement that she had no objection to quashing.
RESPONDENT’S ARGUMENTS (STATE & COMPLAINANT)
The State submitted that, in view of the settlement and complainant’s consent, it did not oppose quashing. The complainant personally confirmed before the Court that the settlement was made voluntarily, that she had received the full amount and articles, and that she had no grievance left.
She clearly stated that she had no objection if proceedings arising from the FIR were quashed. The Investigating Officer also verified the identities and the voluntary nature of the settlement.
ANALYSIS OF THE LAW
The Court emphasised the well-established principle that the inherent jurisdiction of the High Court may be invoked when:
- continuation of proceedings would be futile,
- the dispute is overwhelmingly matrimonial and personal, and
- parties have voluntarily resolved their differences.
Although the offences under Sections 498A/406 IPC are non-compoundable, the High Court can quash them in exercise of inherent powers to prevent abuse of process or secure the ends of justice.
The Court reiterated that matrimonial disputes require a pragmatic and humane approach, especially when parties have already ended their marital relationship by decree of divorce.
PRECEDENT ANALYSIS
The Court relied on several binding authorities, summarised below:
Rangappa Javoor v. State of Karnataka (2023 LiveLaw SC 74)
Principle: Courts should encourage amicable settlements in matrimonial matters; criminal proceedings can be quashed if parties have resolved disputes.
Applied Here: Used to validate settlement-based quashing.
Jitendra Raghuvanshi v. Babita Raghuvanshi (2013) 4 SCC 58
Principle: Even non-compoundable offences arising from matrimonial discord can be quashed under inherent powers when settlement is genuine.
Applied Here: Reinforces legitimacy of quashing despite 498A being non-compoundable.
Gian Singh v. State of Punjab (2012) 10 SCC 303
Principle: High Court may quash proceedings where offence is private in nature and settlement is voluntary.
Applied Here: Recognised that matrimonial disputes fall in this category.
B.S. Joshi v. State of Haryana (2003) 4 SCC
Principle: Criminal proceedings arising from matrimonial differences should be ended when parties settle amicably.
Applied Here: Forms foundational basis for quashing 498A proceedings.
These precedents collectively affirm that amicable settlement in matrimonial matters supersedes the need for criminal prosecution, unless offences are grave or affect society at large.
COURT’S REASONING
The Court found the following key considerations decisive:
- The settlement was genuine, voluntary, and free from coercion, confirmed in Court.
- The marriage had already been dissolved, eliminating the substratum of matrimonial discord.
- The complainant expressly stated she had no objection to quashing and had received the full settlement amount.
- The State also raised no opposition, acknowledging complete closure of the dispute.
The Court concluded that continuing criminal proceedings when both sides wish to move on would amount to abuse of process, noting that Supreme Court and High Court precedents strongly favour quashing in such situations.
CONCLUSION
The High Court held that in the interest of justice, the FIR and all proceedings arising out of it must be quashed. It allowed the petition and quashed the FIR registered under Sections 498A/406/34 IPC, along with all consequential proceedings.
Pending applications were also disposed of.
IMPLICATIONS
- Reinforces that matrimonial offences rooted in personal disputes can be quashed after a genuine settlement.
- Establishes that divorce plus full settlement strengthens grounds for quashing under inherent powers.
- Affirms a pro-conciliation judicial approach in family disputes.
- Clarifies that continuation of prosecution in settled matrimonial cases amounts to harassment and abuse of process.
FAQs
1. Can 498A/406 IPC cases be quashed after a matrimonial settlement?
Yes. Courts routinely quash such cases under inherent powers when settlement is voluntary and genuine.
2. Is divorce necessary before quashing a matrimonial FIR?
Not mandatory, but when divorce has already been granted, courts treat it as strong evidence of final settlement.
3. Does the complainant’s consent matter?
Yes. Explicit consent of the complainant is essential for quashing matrimonial FIRs.
