Facts
The petitioners (the husband and his family members) filed a petition seeking the quashing of FIR No. 80 of 2025, registered at Police Station Mahila Thana, Durg.
Source reference: para. 2The FIR was lodged by Respondent No. 2 (the wife) for offenses under Section 85 read with Section 3(5) of the Bharatiya Nyaya Sanhita (BNS).
Source reference: para. 2During the pendency of the petition, the matter was referred to the Mediation Centre, which reported on 23.03.2026 that the parties had reached a successful settlement.
Source reference: para. 3In accordance with the settlement, the petitioners agreed to pay a total sum of Rs. 17,00,000/- via Demand Drafts to Respondent No. 2.
Source reference: para. 3The Court verified that the full amount was received by Respondent No. 2 after due identification.
Source reference: para. 3-4Issues
Whether the FIR and subsequent criminal proceedings arising from a matrimonial dispute ought to be quashed under the inherent powers of the High Court following a successful mediation and settlement between the parties.
Source reference: para. 5-6Law Applied
The Court applied the settled legal principle that criminal proceedings arising out of matrimonial or personal disputes may be quashed if the parties have reached an amicable settlement and the continuation of the trial would serve no useful purpose or constitute an abuse of the process of law.
Source reference: para. 2, 6The court specifically referenced Section 85 (pertaining to cruelty by husband or relatives) and Section 3(5) (pertaining to joint liability) of the Bharatiya Nyaya Sanhita (BNS).
Source reference: para. 2, 6Reasoning
The Court examined the reports from the Mediation Centre dated 23.03.2026 and 24.03.2026, which confirmed that the parties had voluntarily resolved their disputes.
Source reference: para. 3-4The Court noted that the entire settlement amount of Rs. 17,00,000/- had been duly paid to and received by Respondent No. 2.
Source reference: para. 4Applying the law to these facts, the Court reasoned that because the parties had amicably settled their grievances, the prospect of conviction was remote, and continuing the criminal proceedings would result in an unnecessary burden on the judicial system and the parties involved.
Source reference: para. 5The Court concluded that quashing the FIR was necessary to secure the ends of justice and give effect to the settlement.
Source reference: para. 6Holding
The Court answered the issue in the affirmative, holding that the settlement justified the termination of criminal proceedings.
The Court quashed FIR No. 80 of 2025 registered at Police Station Mahila Thana, Durg, along with all consequential proceedings arising therefrom.
Source reference: para. 6This relief was granted subject to the condition that the petitioners continue to abide by the terms of the settlement.
Source reference: para. 6The petition was allowed.
Source reference: para. 7Original Court PDF
ANKIT SHRIVASTAVAvsSTATE OF CHHATTISGARH
Click to open original judgment
Original judgment, available to read, download and summarize on LawLens.in