Criminal proceedings may be quashed where a private matrimonial dispute is amicably settled.

The petitioners sought quashing of FIR No. 0008/2020, registered at P.S. Lodhi Colony under Sections 323, 341, 506, 509 and 34 of the Indian Penal Code, 1860, and the consequential proceedings in SC No. 278/2023, on the basis of a settlement with respondent no. 2.

The FIR arose from an incident on 13 January 2020, and the parties executed a Settlement Deed dated 11 May 2026.

Petitioner no. 1 and respondent no. 2 appeared in court, petitioner no. 2 joined virtually, and the Investigating Officer identified the parties.

Charges had not yet been framed, and the parties stated that the dispute had been amicably resolved.

1. Whether the FIR and consequential proceedings could be quashed on the basis of the parties’ settlement, given the private and matrimonial nature of the dispute.

2. Whether the court should grant the parties’ joint request to quash the FIR and all proceedings arising from it.

The FIR invoked Sections 323, 341, 506, 509 and 34 of the Indian Penal Code, 1860.

In considering whether proceedings could be quashed following a settlement, the Court relied on Gian Singh v. State of Punjab, (2012) 10 SCC 303, and Narinder Singh v. State of Punjab, (2014) 6 SCC 466. Those decisions guide the exercise of the High Court’s quashing power in cases resolved by settlement, including disputes that are private in nature.

The Court noted that the dispute was matrimonial and private, that the parties had amicably resolved it, and that charges had not yet been framed.

Having regard to those circumstances and the principles in Gian Singh and Narinder Singh, the Court found no impediment to granting the joint request for quashing.

The Court allowed the petition and quashed FIR No. 0008/2020 and all proceedings emanating from it.