Criminal proceedings for matrimonial cruelty quashed following successful court-mandated mediation and amicable settlement between parties.

The petitioners (husband and in-laws) sought the quashing of FIR No. 29/2025 and subsequent criminal proceedings arising from a matrimonial dispute with Respondent No. 4.

The marriage was solemnized on 09.12.2023, but following the birth of a child, relationships strained, leading Respondent No. 4 to lodge a complaint alleging dowry demands and physical/mental cruelty.

Consequently, an FIR was registered on 07.10.2025 for offences under Sections 85 and 3(5) of the Bharatiya Nyaya Sanhita (BNS), 2023, and a charge sheet was filed on 29.11.2025, with the Magistrate taking cognizance on 02.12.2025.

During the pendency of the petition, the High Court directed the parties to mediation, which resulted in a successful amicable settlement dated 16.04.2026.

Whether the High Court, in the exercise of its inherent powers under Section 528 of the Bharatiya Nagrik Suraksha Sanhita (BNSS), 2023, can quash criminal proceedings in non-compoundable matrimonial disputes based on an amicable settlement between the parties.

Section 528 of the Bharatiya Nagrik Suraksha Sanhita (BNSS), 2023 (formerly Section 482 of the CrPC), regarding the inherent powers of the High Court to prevent abuse of the process of law.

Settled legal principles established by the Supreme Court in B.S. Joshi v. State of Haryana (2003) regarding quashing of matrimonial criminal proceedings.

Gian Singh v. State of Punjab (2012) regarding the quashing of non-compoundable offences of a personal nature.

Narinder Singh v. State of Punjab (2014) and Manoj Sharma v. State (2008) regarding the exercise of inherent powers when the possibility of conviction is remote due to settlement.

The Court observed that the dispute between the petitioners and Respondent No. 4 was primarily matrimonial and personal in nature.

It noted that the parties had voluntarily appeared before the High Court Mediation Centre and signed a settlement agreement on 16.04.2026, resolving all grievances.

Applying the ratio of Gian Singh and B.S. Joshi, the Court reasoned that since the parties had settled their private dispute, continuing with the criminal prosecution would serve no fruitful purpose and would be a wastage of judicial time, as the chances of conviction were virtually nil.

The Court emphasized that quashing such proceedings promotes marital harmony or a peaceful parting, serving the ends of justice.

Consequently, the Court quashed FIR No. 29/2025, the charge sheet dated 29.11.2025, and the consequential proceedings in Criminal Case No. 1571/2025 pending before the Judicial Magistrate Class-I, Raigarh, subject to the parties fulfilling the terms of the settlement deed.