High Court Quashes Section 376 IPC Proceedings Based on Settlement to Ensure Victim's Peace and Stability

The Petitioner sought the quashing of FIR No. 0227/2024, registered at P.S. Palam Village under Section 376 of the IPC

The FIR was lodged based on a complaint by Respondent No. 2, who alleged that the Petitioner established a physical relationship with her under a false promise of marriage after meeting on Shaadi.com

Subsequently, the parties entered into a settlement vide a Memorandum of Understanding dated 24.03.2026

Although charges had been framed, the prosecutrix had not yet testified and expressed a desire to move on with her life to maintain peace and stability

1. Whether the High Court should exercise its inherent power to quash criminal proceedings for a non-compoundable offence of a grave nature (Section 376 IPC) on the basis of a compromise between the parties

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which corresponds to Section 482 of the Cr.P.C., regarding the inherent powers of the High Court to secure the ends of justice

Narinder Singh & Ors. vs. State of Punjab & Anr. (2014), which permits quashing non-compoundable cases if the scope of conviction is remote and continuing the trial serves no meaningful purpose

Madhukar & Anr. vs. State of Maharashtra (2025), which held that while Section 376 IPC is heinous, the power to quash is not constrained by a rigid formula and must be exercised based on the facts of each case to ensure the victim's stability and peace

The Court interacted with the parties in chambers to ensure the settlement was voluntary and not coerced

It observed that Respondent No. 2 was a career-oriented individual who wished to terminate the proceedings to ensure personal "peace and stability"

The Petitioner expressed remorse and undertook not to contact the Respondent further

The Court reasoned that since the parties had reached a settlement and the prosecutrix was unwilling to pursue the matter, the likelihood of a productive outcome or conviction was "remote and bleak"

Following the precedent in Madhukar, the Court found that continuing the trial would cause undue distress to the complainant and unnecessarily burden the judicial system

The quashing was made subject to the Petitioner depositing costs of Rs. 25,000/- with the Delhi High Court Legal Services Committee within four weeks

The Court also ordered the correction of the Petitioner's surname in the records from "Alariya" to "Alaria"