FIRs for matrimonial and family disputes quashed following amicable settlement and restoration of matrimonial harmony.

FIR No. 256/2023 was registered by Mr. Satish Khattar against his daughter-in-law, Chhavi Khattar, alleging assault and criminal intimidation

The second, FIR No. 246/2023, was registered by Chhavi Khattar against her in-laws (husband, brother-in-law, and a maternal uncle) alleging outraging of modesty and criminal intimidation

During the pendency of proceedings, the parties were referred to the Delhi Mediation Centre, where they reached a settlement on 09.01.2025, agreeing to resolve all disputes and reside together

Notably, the original complainant in the first FIR, Mr. Satish Khattar, passed away on 18.01.2026

Chhavi Khattar and her husband Anuj Khattar confirmed they are now living in matrimonial harmony

1. Whether the High Court should exercise its inherent powers to quash FIRs in a non-compoundable matrimonial dispute where the parties have amicably settled and are living together.

The court exercised its inherent powers under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (formerly Section 482 of the CrPC) to quash criminal proceedings

The court applied the principle that where a dispute is predominantly private/matrimonial in nature and the parties have reached a settlement, the High Court may quash the proceedings to secure the ends of justice and prevent the abuse of the process of law, especially when the possibility of conviction is remote due to the settlement

The court observed that both cases stemmed from domestic strife between a daughter-in-law and her in-laws. It noted that the parties had already withdrawn related litigation, including a PWDV Act complaint, a maintenance petition, and a divorce petition, pursuant to their mediation agreement

The court interacted with the parties, including the sisters of the deceased complainant Satish Khattar, who expressed no objection to the quashing as the family was now residing in "complete peace"

The court reasoned that since the couple was "enjoying matrimonial bliss" and the dispute involved no "public interest," continuing the criminal proceedings would serve no useful purpose and would be a waste of judicial resources

The petitions were allowed, and the court directed the parties to hand over original affidavits to the concerned SHO/IO within four weeks since charge sheets had not yet been filed