Satyapal Bhati @ Satpal Bhati & Ors. vs The State (Nct Of Delhi ) Tand Anr
- Court
- Delhi High Court
$~92
* IN THE HIGH COURT OF DELHI AT NEW DELHI
% Date of Decision: 05.11.2026
# CNR No. DLHC010537172026
CRL.M.C. 8344/2026, Crl.M.A.34977/2026
+
SATYAPAL BHATI @ SATPAL BHATI & ORS. .....Petitioners
Through: Mr. Puneet Basist and Ms. Kirti
Tanwar, Advs.
versus
THE STATE (NCT OF DELHI ) & ANR .....Respondents
Through: Mr. Utkarsh, APP for State.
ASI Sanjay, PS CWC Nanak Pura
Mr. Vipul Gupta, Adv. for R-2 along
with R-2 in person.
CORAM:
HON'BLE MR. JUSTICE SACHIN DATTA
SACHIN DATTA, J. (ORAL)
1. By way of the present petition filed under Section 528 of the
Bharatiya Nagarik Suraksha Sanhita, 2023 ( pari materia to Section 482 of
the Code of Criminal Procedure, 1973), the petitioners seek quashing of FIR
No. 0015/2024, dated 10.04.2024, registered at P.S. Crime (Women) Cell,
Nanak Pura, Delhi, under Sections 498A/406/34/354A/506 IPC of the Indian
Penal Code, 1860 (“IPC”), together with all proceedings emanating
therefrom, on the basis of the Settlement Agreement, dated 04.02.2026,
entered into between the parties. The same is appended as Annexure P-3 to
the present petition.
2. Petitioner no.1 and respondent no.2 were married on 25.11.2013,
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CRL.M.C. 8344/2026 Page 1 of 10
Digitally Signed
By:ABHISHEK THAKUR
Signing Date:07.11.2026
11:51:09
according to Hindu rites and ceremonies in Delhi. Two sons were born out
of the said wedlock, on 14.02.2017 and 24.08.2018 respectively, both of
whom are in the care and custody of respondent no.2. On account of
temperamental differences, the parties have been living separately since
22.08.2023.
3. The subject FIR came to be registered on the complaint of respondent
no.2 alleging demands of dowry, cruelty and retention of stridhan. In the
course of investigation, Sections 354A and 506 IPC came to be added.
4. It is pointed out that the parties have settled all their disputes before
the Delhi Mediation Centre, Tis Hazari Courts, Delhi, on 04.02.2026.
5. The material terms of the settlement arrived at in the mediation
proceedings dated 04.02.2026 are as under:
“Terms & Schedule of Settlement :
After understanding the process of mediation, aforesaid legal
position involved in the settlement, the parties have arrived at an
amicable settlement on the terms and conditions as under :-
1. It is agreed between husband and wife that there is no possibility
of reunion due to irreconcilable differences and as such, they have
decided to separate their ways and go for dissolution of their
marriage by mutual consent in accordance with law as provided
under section 13B of Hindu Marriage Act, 1955.
*
4. It has been agreed between the parties that the husband Mr.
Satyapal Bhati @ Satpal Bhati shall pay a total sum of
₹1,50,00,000/ - (Rupees one crore fifty lakhs only) to wife Ms.
[respondent no.2] towards full and final settlement of all her claims
including Istridhan, maintenance (present, past and future) and
permanent alimony etc.
5. That aforementioned settlement amount of ₹1,50,00,000/ -
(Rupees one crore fifty lakhs only) shall be paid in the following
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Digitally Signed
By:ABHISHEK THAKUR
Signing Date:07.11.2026
11:51:09
manner:-
(1) ₹50,00,000/ - (Rupees fifty lakhs only) - DD No.114292 drawn
on Punjab National Bank Loni, Ghaziabad in the name of the wife -
At the time of recording statements of parties in first motion under
section 13B(1) HMA;
(2) ₹50,00,000/ - (Rupees fifty lakhs only) - Electronic mode/ DD in
the name of minor son - At the time of recording statements of
parties in first motion under section 13B(2) HMA;
(3) ₹50,00,000/ - (Rupees fifty lakhs only) - Electronic mode/ DD in
the name of minor son - At the time of quashing of the FIR before
Hon’ble High Court against the accused persons named in FIR (as
stated hereinabove).
6. The wife undertakes that out of the above said settlement amount
of ₹1,50,00,000/ - (Rupees one crore fifty lakhs only), a sum of
₹1,00,00,000/ - (Rupees one core only) will be used for the welfare/
education of both the minor children.
7. It is also agreed between the parties that the permanent custody
of both the minor children shall remain with their mother/ the wife
and she will be the sole guardian of both the minor children. The
husband undertakes that he will not claim custody / visitation rights
towards the minor children in future.
*
9. It is further agreed between the parties that on completion of
terms agreed above, they shall not be left with any claims towards
each other and shall not litigate in future against each other qua
this marriage.
*
Withdrawal/ Disposal :
It is agreed between the parties that Mr. Satyapal Bhati @ Satpal
Bhati (husband) and his family members namely Sh. Ratan Singh
Bhati (father-in-law), Smt Viramvati @ Virambati (mother-in-law),
Sh. Chain Pal (brother-in-law) and Sh. Phirey Singh (Chachia
susar), who are accused persons in the FIR No. 15/2024 shall file
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Digitally Signed
By:ABHISHEK THAKUR
Signing Date:07.11.2026
11:51:09
quashing petition before Hon’ble High Court within one month
after grant of second motion petition and wife shall cooperate in
quashing of the FIR and proceedings emanating therefrom against
the above named accused persons including filing of affidavit and
appearance in the Hon’ble High Court for the said purpose.
*
Free Consent of the Parties :
The parties, unequivocally declare that they have executed this
agreement voluntarily, after fully understanding and appreciating
the contents, scope, and effect thereof, as well as the consequences
of the breach thereof along with the legal position explained
hereinabove. They further declare that they are signing this
agreement voluntarily after examining all probabilities and
implications thereof, and without any kind of force, pressure, undue
influence, misrepresentation, or mistake (both of law and fact), in
any form, whatsoever, from any quarter.”
6. During the course of hearing, a bank draft of Rs.50,00,000/-, being the
balance settlement amount, has been handed over to respondent no.2. The
respondent no.2 confirms the receipt thereof.
7. The respondent no.2 as also the petitioners, have been identified by
the concerned Investigating Officer, who is present in Court.
8. The respondent no.2 affirms that she has settled the matter of her own
free will and volition, and without any undue pressure or influence. She has
also placed on record an affidavit to the said effect, stating that she has no
objection to the quashing of the subject FIR as against the petitioners.
9. In terms of the settlement, the marriage between petitioner no.1 and
respondent no.2 stands dissolved by a decree of divorce by mutual consent
under Section 13B of the Hindu Marriage Act, 1955, as on 09.04.2026.
10. It is evident that the disputes between the parties arise wholly out of
the matrimonial relationship and are private in character.
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Digitally Signed
By:ABHISHEK THAKUR
Signing Date:07.11.2026
11:51:09
11. In this regard, it is apposite to refer to the decision of the Supreme
Court in Gian Singh v. State of Punjab , (2012) 10 SCC 303 , wherein it was
observed as under:
“ 58. Where the High Court quashes a criminal proceeding having
regard to the fact that the dispute between the offender and the
victim has been settled although the offences are not
compoundable, it does so as in its opinion, continuation of
criminal proceedings will be an exercise in futility and justice in
the case demands that the dispute between the parties is put to an
end and peace is restored; securing the ends of justice being the
ultimate guiding factor. No doubt, crimes are acts which have
harmful effect on the public and consist in wrongdoing that seriously
endangers and threatens the well-being of the society and it is not
safe to leave the crime-doer only because he and the victim have
settled the dispute amicably or that the victim has been paid
compensation, yet certain crimes have been made compoundable in
law, with or without the permission of the court. In respect of serious
offences like murder, rape, dacoity, etc., or other offences of mental
depravity under IPC or offences of moral turpitude under special
statutes, like the Prevention of Corruption Act or the offences
committed by public servants while working in that capacity, the
settlement between the offender and the victim can have no legal
sanction at all. However, certain offences which overwhelmingly
and predominantly bear civil flavour having arisen out of civil,
mercantile, commercial, financial, partnership or such like
transactions or the offences arising out of matrimony, particularly
relating to dowry, etc. or the family dispute, where the wrong is
basically to the victim and the offender and the victim have settled
all disputes between them amicably, irrespective of the fact that
such offences have not been made compoundable, the High Court
may within the framework of its inherent power, quash the
criminal proceeding or criminal complaint or FIR if it is satisfied
that on the face of such settlement, there is hardly any likelihood of
the offender being convicted and by not quashing the criminal
proceedings, justice shall be casualty and ends of justice shall be
defeated.
The above list is illustrative and not exhaustive. Each case
will depend on its own facts and no hard-and-fast category can be
prescribed. ”
(emphasis supplied)
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CRL.M.C. 8344/2026 Page 5 of 10
Digitally Signed
By:ABHISHEK THAKUR
Signing Date:07.11.2026
11:51:09
12. The principles established in Gian Singh (supra) were further
crystallised in Narinder Singh v. State of Punjab , (2014) 6 SCC 466 .
Paragraph 29 of the same reads as follows:
“ 29. In view of the aforesaid discussion, we sum up and lay down the
following principles by which the High Court would be guided in
giving adequate treatment to the settlement between the parties and
exercising its power under Section 482 of the Code while accepting
the settlement and quashing the proceedings or refusing to accept
the settlement with direction to continue with the criminal
proceedings:
*
29.2. When the parties have reached the settlement and on that
basis petition for quashing the criminal proceedings is filed, the
guiding factor in such cases would be to secure:
(i) ends of justice, or
(ii) to prevent abuse of the process of any court.
While exercising the power the High Court is to form an opinion on
either of the aforesaid two objectives.
*
29.4. On the other hand, those criminal cases having
overwhelmingly and predominantly civil character, particularly
those arising out of commercial transactions or arising out of
matrimonial relationship or family disputes should be quashed
when the parties have resolved their entire disputes among
themselves
.
29.5. While exercising its powers, the High Court is to examine as to
whether the possibility of conviction is remote and bleak and
continuation of criminal cases would put the accused to great
oppression and prejudice and extreme injustice would be caused to
him by not quashing the criminal cases
. ”
(emphasis supplied)
13. Specifically in the context of matrimonial disputes, the Supreme
Court in Jitendra Raghuvanshi v. Babita Raghuvanshi , (2013) 4 SCC 58 ,
remarked as under:
“ 14. The inherent powers of the High Court under Section 482 of
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Digitally Signed
By:ABHISHEK THAKUR
Signing Date:07.11.2026
11:51:09
the Code are wide and unfettered. In B.S. Joshi [(2003) 4 SCC 675:
2003 SCC (Cri) 848], this Court has upheld the powers of the High
Court under Section 482 to quash criminal proceedings where
dispute is of a private nature and a compromise is entered into
between the parties who are willing to settle their differences
amicably. We are satisfied that the said decision is directly
applicable to the case on hand and the High Court ought to have
quashed the criminal proceedings by accepting the settlement
arrived at.
15. In our view, it is the duty of the courts to encourage genuine
settlements of matrimonial disputes, particularly, when the same
are on considerable increase. Even if the offences are non-
compoundable, if they relate to matrimonial disputes and the
Court is satisfied that the parties have settled the same amicably
and without any pressure, we hold that for the purpose of
securing ends of justice, Section 320 of the Code would not be a
bar to the exercise of power of quashing of FIR, complaint or the
subsequent criminal proceedings
. ”
(emphasis supplied)
14. It is noticed that the allegations under Section 354A IPC, which came
to be added in the course of investigation and in respect of which only
petitioner no.5 has been chargesheeted, relate to a single incident alleged to
have occurred on 31.12.2023, during the course of the subsisting
matrimonial disputes. While this Court is conscious of the gravity of an
allegation of this nature, having interacted with respondent no.2, this Court
is nonetheless of the view that the continuation of the proceedings, even qua
petitioner no.5, is unwarranted, for the following reasons:
(i) the settlement is comprehensive and expressly covers
petitioner no.5, against whom the said allegation was made;
(ii) respondent no.2 has affirmed, during the course of
hearing, that the allegation was made on account of a
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Digitally Signed
By:ABHISHEK THAKUR
Signing Date:07.11.2026
11:51:09
misunderstanding, and that she is not desirous of persuing it;
(iii) the allegation forms part of the very same complaint and
arises in the course of the same marital discord; and
(iv) the marriage between petitioner no.1 and respondent no.2
stands dissolved and the entire settlement amount stands paid. To
continue the prosecution qua petitioner no.5 alone would compel
respondent no.2 to depose against her own categorical stand,
years after the relationship between the parties has come to an
end. As such, the continuation of the proceedings would be an
exercise in futility.
15. It is also apposite to refer to the decision of a coordinate Bench of this
Court in Prateek & Ors. v. State NCT of Delhi & Anr. , CRL.M.C.
6676/2024, decided on 28.08.2024. In the said case, the chargesheet had
been filed against the brother-in-law of the complainant under Sections
498A/354/354A/34 IPC. This Court, whilst recognising that offences under
Sections 354 and 354A IPC are serious in nature, nonetheless quashed the
FIR by holding that the complainant having moved on in life, the
continuation of the proceedings would only result in further harassment to
the parties and would amount to an abuse of the process of the Court. The
relevant extracts read as under:
“14. It is not in doubt that the offences under Sections
354/354A/377 of the IPC are heinous in nature and involve mental
depravity. Such offences cannot be quashed merely because the
victim has settled the dispute. Such offences, in true sense, are not
private in nature.
*
18. However, as noted above, the complainant has since moved on
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Digitally Signed
By:ABHISHEK THAKUR
Signing Date:07.11.2026
11:51:09
in her life. In such circumstances, the continuation of
proceedings would only cause further undue harassment and
heartburn to the parties.
19. Keeping in view the nature of dispute and that the parties have
amicably entered into a settlement, this Court feels that no useful
purpose would be served by keeping the dispute alive and
continuance of the proceedings would amount to abuse of the
process of Court.
I am of the opinion that this is a fit case to
exercise discretionary jurisdiction under Section 482 of the CrPC.”
(emphasis supplied)
16. Similarly, in Rajat Bhatia & Ors. v. State NCT of Delhi & Anr. ,
CRL.M.C. 1066/2025, decided on 30.04.2025, an FIR registered under
Sections 498A/406/354A/509 IPC was quashed upon the parties having
dissolved their marriage by mutual consent and having settled their disputes.
The relevant paragraph reads as under:
“17. In these circumstances, in line with the law laid down by the
Supreme Court in Gian Singh vs. State of Punjab & Anr.: (2012) 10
SCC 303 as also in Narinder Singh & Ors. vs. State of Punjab &
Anr.: (2014) 6 SCC 466, this Court sees no reason why the subject
FIR and all proceedings emanating therefrom should not be
quashed. In light of the settlement between the contesting parties,
continuing with the subject FIR and all subsequent proceedings
would be a futile exercise and would not be conducive to peace and
harmony between the parties.”
17. In the circumstances, the settlement dated 04.02.2026 furnishes a
cogent basis for quashing the subject FIR. The prosecution arises out of
private matrimonial disputes which the parties have voluntarily resolved,
and its continuation would serve no fruitful purpose.
18. Considering the circumstances and the dicta laid down in the
aforesaid judgments, there is no impediment to allowing the present petition.
19. Accordingly, the present petition is allowed. FIR No. 0015/2024,
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Digitally Signed
By:ABHISHEK THAKUR
Signing Date:07.11.2026
11:51:09
dated 10.04.2024, registered at P.S. Crime (Women) Cell, Nanak Pura,
Delhi, under Sections 498A/406/34/354A/506 IPC, and all proceedings
emanating therefrom, qua all the petitioners, stand quashed.
20. Since considerable judicial time and State resources have been
consumed on account of the subject FIR, the petitioners agree to pay costs of
₹1,00,000/ - to the Delhi High Court Legal Services Committee (DHCLSC).
21. It is undertaken that the costs shall be deposited within a period of
four weeks from today, and proof of payment shall be filed in the Registry
of this Court. The said undertaking is accepted and taken on record.
22. The petition stands disposed of in the above terms.
23. The pending application also stands disposed of.
SACHIN DATTA, J
cl/sd
NOVEMBER 5, 2026/
]
Signature Not Verified
CRL.M.C. 8344/2026 Page 10 of 10
Digitally Signed
By:ABHISHEK THAKUR
Signing Date:07.11.2026
11:51:09