Chhattisgarh High Court

Criminal proceedings under Section 498A IPC quashed upon voluntary settlement and reconciliation of parties.

Shekhar Gupta & Others v. State of Chhattisgarh & Another [2026:CGHC:9454-DB (CRMP No. 2513 of 2025)]

Chhattisgarh High Court2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners (the husband and his relatives) filed a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, seeking to quash FIR No. 0031/2024 registered at Police Station Mahila-Thana, Ambikapur.

Source reference: p.2

The FIR alleged offences under Section 498A of the Indian Penal Code (IPC).

Source reference: p.2

Following the investigation, a charge-sheet was filed on May 1, 2025, and the Judicial Magistrate First Class, Ambikapur, took cognizance of the matter on May 2, 2025, registering Criminal Case No. 3567/2025.

Source reference: p.3

During the pendency of these proceedings, the husband (Petitioner No. 1) and the wife (Respondent No. 2) entered into a compromise deed dated January 12, 2026, to settle their matrimonial disputes amicably outside of court.

Source reference: p.3
02

Issues

1. Whether the High Court should exercise its inherent powers to quash criminal proceedings under Section 498A of the IPC when the parties have reached a voluntary, amicable settlement.

Source reference: p.4
03

Law Applied

The court exercised its inherent powers under Section 528 of the BNSS (which corresponds to Section 482 of the CrPC) to prevent the abuse of the process of law and secure the ends of justice.

Source reference: p.2

The court applied the principle that in matrimonial disputes of a personal nature, where a settlement has been reached without coercion or undue influence, criminal proceedings may be quashed to facilitate reconciliation and peace between the parties.

Source reference: p.4
04

Reasoning

The Court observed that the dispute between the parties was essentially matrimonial and had been settled through a mutual compromise deed filed on record.

Source reference: p.3

Upon perusing the materials, the Court found that the settlement was voluntary and lacked any evidence of coercion or undue influence.

Source reference: p.4

The Court reasoned that since the parties had reconciled and settled their grievances, the continuation of the criminal trial would be unwarranted and would serve no further purpose in the interest of justice.

Source reference: p.4

Consequently, the Court determined that quashing the proceedings was necessary to give effect to the parties' intent to resolve the matter through mutual consent.

Source reference: p.4
05

Holding

The High Court allowed the petition and quashed FIR No. 0031/2024, the charge-sheet dated May 1, 2025, and the cognizance order dated May 2, 2025, along with all consequential proceedings in Criminal Case No. 3567/2025.

The quashing is subject to the fulfillment of the terms and conditions outlined in the compromise deed dated January 12, 2026.

Source reference: p.4
Chhattisgarh High Court

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Shekhar Gupta & Others v. State of Chhattisgarh & Another [2026:CGHC:9454-DB (CRMP No. 2513 of 2025)]

Chhattisgarh High Court

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