High Courts may quash matrimonial criminal proceedings under Section 482 CrPC after parties compromise.

The petitioners in Criminal Miscellaneous No. 21378 of 2024 were the father-in-law and mother-in-law of Opposite Party No. 2, while the petitioner in Criminal Miscellaneous No. 21821 of 2024 was her husband

Opposite Party No. 2 alleged that the accused persons subjected her to physical, mental, and economic torture, and that her husband demanded money and had forcibly taken ₹1,00,000 from her father in 2010

In Gandhi Maidan P.S. Case No. 864 of 2022, the Sub-Divisional Judicial Magistrate, Patna, took cognizance under Sections 341, 323, 498A, 504, and 506 read with Section 34 of the Indian Penal Code by order dated 19 May 2023

During the proceedings, the parties entered into a compromise. A decree of divorce by mutual consent was passed on 19 November 2025 in Matrimonial Case No. 563 of 2025, and the related guardianship proceedings were withdrawn

Opposite Party No. 2 did not oppose the quashing applications and supported the compromise

Whether the High Court should exercise its inherent jurisdiction under Section 482 of the Code of Criminal Procedure to quash the cognizance order and consequential criminal proceedings arising from matrimonial offences after the parties have amicably settled their dispute?

Whether the compromise, mutual-consent divorce, withdrawal of connected proceedings, and absence of opposition by the complainant justified bringing the criminal prosecution to an end in the interests of justice?

The Court applied Section 482 of the Code of Criminal Procedure, which preserves the High Court’s inherent power to prevent abuse of the process of any court and to secure the ends of justice.

It considered the offences alleged under Sections 341, 323, 498A, 504, and 506 read with Section 34 of the Indian Penal Code

Relying on Gian Singh v. State of Punjab, (2012) 10 SCC 303, and Mange Ram v. State of Madhya Pradesh & Anr., 2025 INSC 962, the Court reiterated that criminal proceedings arising predominantly from matrimonial and personal disputes may be quashed where the parties have genuinely compromised, particularly when continuation of the prosecution would serve no useful purpose and quashing would promote the ends of justice

The Court did not examine the allegations on their merits. Instead, it relied on the subsequent settlement between the parties, the mutual-consent divorce decree, withdrawal of the connected guardianship proceedings, and the complainant’s clear non-opposition to the quashing applications

Since the dispute arose out of matrimonial relations and had been comprehensively settled, the Court held that continuing the prosecution would be unnecessary.

Applying the principles in Gian Singh and Mange Ram, it concluded that exercising inherent jurisdiction under Section 482 CrPC was appropriate to secure the ends of justice and bring a peaceful finality to the litigation

It quashed the order dated 19 May 2023 passed by the Sub-Divisional Judicial Magistrate, Patna, taking cognizance in Gandhi Maidan P.S. Case No. 864 of 2022, along with all consequential criminal proceedings arising from that case, insofar as they related to the petitioners