Criminal proceedings arising from matrimonial disputes may be quashed upon genuine settlement between spouses.

In brief

The question

Whether the FIRs and criminal proceedings arising from the matrimonial dispute could be quashed in exercise of the High Court’s jurisdiction in view of the parties’ amicable settlement and the consent of the complainant.

The court held

The Court answered the issues in favour of the petitioner.

It also directed

Tura P.S. Case No. 12 of 2025 and Tura P.S. Case No. 28 of 2025, registered at the instance of Respondent No. 6, were quashed and set aside.

The criminal petition was accordingly allowed and disposed of on the settlement terms.

01Facts

The petitioner and Respondent No. 6, Jitherson A. Sangma, are husband and wife.

p. 2 · ¶ 1–2

At the instance of Respondent No. 6, Tura P.S. Case No. 12 of 2025 and Tura P.S. Case No. 28 of 2025 were registered against the petitioner.

p. 2 · ¶ 1–2

The petitioner sought quashing of both proceedings before the High Court.

p. 2 · ¶ 1–2

Considering the matrimonial relationship, the Court referred the parties to mediation, which resulted in a successful settlement dated 5 August 2026.

pp. 2–3 · ¶ 3–4

Under the settlement, Respondent No. 6 agreed to withdraw his allegations and complaints, consent to quashing, and take necessary steps for closure of the proceedings.

p. 3 · ¶ 5–6

The parties also exchanged agreed properties and belongings, including land pattas handed over by the petitioner and a vehicle handed over by Respondent No. 6.

pp. 4–5 · ¶ 7

02Issues

i.Whether the FIRs and criminal proceedings arising from the matrimonial dispute could be quashed in exercise of the High Court’s jurisdiction in view of the parties’ amicable settlement and the consent of the complainant.

p. 5 · ¶ 8

ii.Whether, having regard to the nature of the dispute and the settlement between the spouses, continuation of Tura P.S. Case Nos. 12 of 2025 and 28 of 2025 would serve any legitimate prosecutorial purpose.

p. 5 · ¶ 8

03Law Applied

The Court applied the principles governing quashing of criminal proceedings on the basis of a genuine settlement between the parties, as recognised by the Supreme Court in Gian Singh v. State of Punjab & Anr., (2012) 10 SCC 303, and Narinder Singh & Ors. v. State of Punjab, (2014) 6 SCC 466.

p. 5 · ¶ 8

These authorities permit quashing of proceedings involving predominantly private or matrimonial disputes where the parties have genuinely settled their differences and continuation of the prosecution would not advance the interests of justice.

p. 5 · ¶ 8

The Court also considered the parties’ matrimonial relationship and the voluntary undertaking of the complainant to withdraw and support quashing of the proceedings.

p. 5 · ¶ 8

Provisions in the judgment · 5 · Linked ones open on LawLens

Bharatiya Nyaya Sanhita, 2023 Section 112 Section 329 Section 305

Indian Penal Code, 1860 Section 420 Section 468

04Reasoning

The Court found that mediation had resulted in a comprehensive and voluntary settlement between the spouses.

pp. 3–4 · ¶ 5–6

Respondent No. 6 had unequivocally agreed to withdraw his allegations, consent to quashing, and support closure of the FIRs and related proceedings.

pp. 3–4 · ¶ 5–6

The dispute arose from the matrimonial relationship and was therefore predominantly private in nature.

pp. 4–5 · ¶ 7–8

In light of the settlement, the exchange of property and belongings, and the complainant’s express non-opposition, the Court held that there was no impediment to quashing the proceedings under the principles laid down in Gian Singh and Narinder Singh.

pp. 4–5 · ¶ 7–8