High Courts may quash matrimonial-cruelty proceedings under inherent powers after parties amicably settle disputes.

The petitioner, Nishit Ranjan, was the husband of opposite party no. 2, Shalu Verma.

Opposite party no. 2 lodged Shashtri Nagar P.S. Case No. 798 of 2023 dated 18 August 2023, alleging matrimonial cruelty and offences under Sections 341, 342, 323 and 498A of the Indian Penal Code.

The petitioner contended that the allegations arose from matrimonial discord and were false and exaggerated.

The parties initially executed a Memorandum of Understanding-cum-Compromise dated 23 January 2024, but it was not acted upon.

Subsequently, on 7 May 2026, they jointly resolved their disputes and filed a compromise petition before the learned A.C.J.M.-IX, Patna Sadar, stating that the FIR had resulted from misunderstanding and temperamental differences and that the settlement was voluntary and free from coercion.

Opposite party no. 2 supported the compromise and stated that she did not wish to pursue the criminal case and had no objection to its quashing.

Whether the High Court should exercise its inherent jurisdiction to quash an FIR alleging offences under Sections 341, 342, 323 and 498A IPC on the basis of a voluntary compromise between the husband and wife?

Whether continuation of the criminal proceedings, after settlement of the matrimonial dispute, would amount to an abuse of the process of the Court?

The Court considered the offences alleged under Sections 341, 342, 323 and 498A of the Indian Penal Code and applied the High Court’s inherent jurisdiction to prevent abuse of the process of law and secure the ends of justice.

Relying on Mange Ram v. State of Madhya Pradesh & Anr., [2025] INSC 962, the Court held that in cases arising from matrimonial discord, where the parties have voluntarily compromised their disputes, the Court may exercise its inherent powers to quash the criminal proceedings when their continuation would merely amount to an abuse of the process of the Court.

The Court found that the dispute was essentially matrimonial in nature and that the parties had subsequently resolved their differences through a joint compromise.

The compromise was supported by both the petitioner and opposite party no. 2, and there was no indication of force, coercion or undue influence.

Applying the principle in Mange Ram, the Court held that continuing the prosecution despite the settlement would serve no useful purpose and would only create further bitterness between the spouses.

In these circumstances, giving a peaceful quietus to the proceedings was considered appropriate.

It held that, in view of the voluntary compromise and the matrimonial character of the dispute, continuation of the criminal proceedings would amount to an abuse of the process of the Court.

Accordingly, Shashtri Nagar P.S. Case No. 798 of 2023 dated 18 August 2023, registered under Sections 341, 342, 323 and 498A IPC, was quashed, and the criminal miscellaneous application was allowed.