Chhattisgarh High Court

Criminal revision in matrimonial disputes may be disposed of based on a voluntary settlement.

SMT. ABHA SAHU vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 23, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant (wife) and respondent no. 2 (husband) were married on 15.02.2013

Source reference: para. 3

The 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. 3

After being deserted in 2015, the applicant filed a complaint under Section 498A read with Section 34 of the IPC

Source reference: para. 3

The Judicial Magistrate First Class, Bilaspur, acquitted the respondent on 14.09.2021, citing a lack of sufficient evidence

Source reference: para. 2

This acquittal was subsequently affirmed by the 3rd Additional Session Judge, Bilaspur, on 08.06.2023

Source reference: para. 2

The applicant challenged these concurrent findings through the present criminal revision

Source reference: para. 2

During 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. 4
02

Issues

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. 9
03

Law 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. 2

In 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. 9
04

Reasoning

The Court noted that the dispute was essentially matrimonial in nature and had been resolved independently by the parties

Source reference: para. 5, 8

Pursuant 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. 7

The 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, 9

The 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. 9
05

Holding

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. 10

No further grievance or litigation survived between the parties

Source reference: para. 5
Chhattisgarh High Court

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SMT. ABHA SAHUvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · March 23, 2026

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