Amicable settlement of matrimonial disputes justifies quashing of non-compoundable criminal proceedings to prevent abuse of process.

The Applicants filed an application under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, seeking the quashing of a charge-sheet dated April 20, 2025, and a summoning order dated March 9, 2026

The proceedings originated from Criminal Case No. 101 of 2026, involving allegations under Section 498A of the Indian Penal Code (IPC) and Sections 3/4 of the Dowry Prohibition Act

During the pendency of the application, the parties filed a joint Compounding Application (I.A. No. 01 of 2026), stating that the matrimonial dispute had been amicably settled

The parties appeared before the Court (Applicant No. 2 via video conferencing) and expressed their desire to terminate the proceedings

Whether the High Court, in the exercise of its inherent powers under Section 528 of the BNSS, should quash criminal proceedings involving non-compoundable matrimonial offences when the parties have reached an amicable settlement

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (the successor to Section 482 of the CrPC), which saves the inherent power of the High Court to make such orders as may be necessary to prevent abuse of the process of any Court or otherwise to secure the ends of justice

in cases arising out of matrimonial disputes, the High Court may quash proceedings if a settlement is reached, as the interest of justice outweighs the technicality of the non-compoundable nature of the offences

the dispute was "essentially matrimonial in nature" and that the parties had voluntarily entered into a settlement as evidenced by the joint Compounding Application and supported affidavits

despite the State Counsel’s objection that some offences were non-compoundable, the Court determined that since the parties no longer wished to pursue the matter, the trial's continuation would be futile

forced litigation in the face of an amicable settlement would "serve no useful purpose" and would instead amount to an "abuse of the process of law"

The Court held that quashing was necessary in the interest of justice

the Criminal Miscellaneous Application filed under Section 528 of the BNSS was disposed of