Facts
The applicant (wife) and respondent no. 2 (husband) were married on 15.02.2013
Source reference: para. 3The applicant alleged that following the marriage, the respondent and his family demanded a dowry of Rs. 20,00,000 and subjected her to physical and mental cruelty
Source reference: para. 3After being deserted in 2015, the applicant filed a complaint under Section 498A read with Section 34 of the IPC
Source reference: para. 3The Judicial Magistrate First Class, Bilaspur, acquitted the respondent on 14.09.2021, citing a lack of sufficient evidence
Source reference: para. 2This acquittal was subsequently affirmed by the 3rd Additional Session Judge, Bilaspur, on 08.06.2023
Source reference: para. 2The applicant challenged these concurrent findings through the present criminal revision
Source reference: para. 2During the pendency of this revision, the parties reached an amicable settlement before the Family Court, Bilaspur, where the respondent agreed to pay Rs. 6,00,000 as a full and final settlement
Source reference: para. 4Issues
Whether the High Court can exercise its revisional jurisdiction to dispose of a criminal proceeding arising from matrimonial disputes on the basis of a voluntary compromise between the parties
Source reference: para. 9Law Applied
The Court exercised its revisional jurisdiction under Section 397 read with Section 401 of the Code of Criminal Procedure (Cr.P.C.), 1973
Source reference: para. 2In matters arising from matrimonial discord, where parties have amicably resolved their differences, the Court may intervene to secure the ends of justice and prevent abuse of the legal process
Source reference: para. 9Reasoning
The Court noted that the dispute was essentially matrimonial in nature and had been resolved independently by the parties
Source reference: para. 5, 8Pursuant to the Court's direction on 16.02.2026, the Additional Registrar (Judicial) verified the compromise, certifying that it was entered into voluntarily and without coercion
Source reference: para. 7The Court reasoned that since the parties had decided to give "quietus" to their disputes and the respondent had fulfilled the financial terms of the settlement (Rs. 6,00,000), no grievance survived
Source reference: para. 4, 9The Court determined that continuing the criminal revision against the concurrent judgments of acquittal would be an "exercise in futility" given the restoration of harmony and the parties' desire to live independently
Source reference: para. 9Holding
The High Court disposed of the Criminal Revision in terms of the compromise arrived at between the parties
The Court held that the amicable settlement effectively resolved the matrimonial dispute, and the compromise deed was ordered to form part of the final order
Source reference: para. 10No further grievance or litigation survived between the parties
Source reference: para. 5Original Court PDF
SMT. ABHA SAHUvsSTATE OF CHHATTISGARH
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