Criminal proceedings arising from matrimonial disputes may be quashed under inherent powers upon mutual settlement.

The petitioners, comprising the wife (Petitioner No. 1) and her natal family (Petitioners No. 2–5), sought the quashing of FIR No. 45/2025 and subsequent criminal proceedings initiated by the husband (Respondent No. 3)

The husband alleged that on 27.01.2025, the petitioners forcibly entered his residence, assaulted family members, and removed dowry articles, jewelry, and ₹40,000 in cash using a truck

Following an investigation, a chargesheet was filed on 30.10.2025 under Sections 296, 115(2), 351(2), 191(2), and 310(2) of the Bharatiya Nyaya Sanhita (BNS), 2023

During the pendency of the criminal case, the High Court directed the parties to explore mediation on 06.02.2026

Consequently, on 19.02.2026, the parties entered into a comprehensive settlement agreement involving mutual consent divorce and the withdrawal of all pending matrimonial and maintenance litigations

Whether the High Court should exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, to quash criminal proceedings arising from a matrimonial dispute where the parties have reached a voluntary compromise

Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (formerly Section 482 of the CrPC), which preserves the High Court's inherent power to secure the ends of justice or prevent abuse of the court's process

Landmark principles established in Gian Singh v. State of Punjab [2012 (10) SCC 303], which distinguishes between heinous crimes and private/matrimonial disputes that have an "overwhelmingly civil flavour," permitting quashing in the latter if a settlement is reached

Narinder Singh & Others v. State of Punjab [2014 (6) SCC 466], emphasizing that the timing of a settlement is crucial and courts may be liberal in accepting compromises arrived at early in the proceedings

Reference was also made to B. S. Joshi & others v. State of Haryana [2003 (4) SCC 675] regarding the quashing of matrimonial offenses to encourage social harmony

The Court observed that the dispute between the parties was essentially matrimonial and private in nature

Upon reviewing the mediation report dated 19.02.2026, the Court noted that the parties had resolved all grievances, including the division of property and the decision to dissolve the marriage by mutual consent

Applying the ratio from Gian Singh, the Bench reasoned that since the parties had "buried the dispute," the possibility of conviction had become "remote and bleak"

The Court concluded that requiring the petitioners to face trial despite a complete settlement would result in "great oppression and prejudice" and constitute an unnecessary drain on judicial resources

Furthermore, the State expressed no objection to the quashing of the proceedings in light of the settlement

The holding was made subject to the parties fulfilling the specific terms and conditions outlined in their compromise agreement dated 19.02.2026

The Court held that quashing was necessary to secure the ends of justice as the continuation of proceedings would amount to an abuse of the process of law