After Settlement, Karnataka HC Quashes Dowry-Harassment Proceedings Against Three In-Laws Only

Respondent No. 2 complained that, after her marriage to accused No. 1 on 12 July 2017, the petitioners—accused Nos. 2 to 4 and her in-laws—mentally and physically harassed her and demanded dowry.

Crime No. 100/2023 was registered under Sections 498A, 323, 504 and 506 read with Section 34 of the IPC, and Sections 3 and 4 of the Dowry Prohibition Act; investigation was pending when the petitioners sought to quash the proceedings under Section 482 CrPC/Section 528 BNSS.

The petitioners filed a memo stating that the parties had settled the matter by compromise before the High Court in W.P. No. 104784/2024 on 24 April 2026.

Section 482 CrPC (and Section 528 BNSS, as invoked in the petition) preserves the High Court’s inherent power to quash criminal proceedings, including proceedings for non-compoundable offences, where doing so is necessary to secure the ends of justice or prevent abuse of process.

In Narinder Singh v. State of Punjab, (2014) 6 SCC 466, the Supreme Court held that this power must be exercised sparingly; settlement may justify quashing where the dispute is predominantly private, including a matrimonial or family dispute, and the court is satisfied that the possibility of conviction is remote and continuation would cause unnecessary oppression.

Serious offences affecting society are generally not to be quashed merely on the basis of compromise

The Court treated the allegations as arising from a matrimonial and family dispute and noted that the parties had settled by compromise.

As investigation was still pending, the Court considered the likelihood of conviction to be minimal and concluded that continuing the prosecution against the petitioners was unnecessary and would amount to an abuse of process.

Applying the principles in Narinder Singh, it accepted the settlement and the petitioners’ memo

Pending interlocutory applications were disposed of as no longer requiring consideration