High Courts may quash non-compoundable matrimonial proceedings upon a genuine settlement between the parties.

The petitioners sought quashing of FIR No. 518/2023, registered under Sections 498A, 406, 506, 323 and 34 of the IPC and Section 4 of the Dowry Prohibition Act, arising from matrimonial allegations by respondent no. 2.

The parties entered into a settlement on 4 November 2025, under which petitioner no. 1 agreed to pay respondent no. 2 ₹7,00,000 in full and final settlement; the balance of ₹2,40,000 was paid by demand draft in Court.

Their marriage had been dissolved by mutual-consent decree, and respondent no. 2 had withdrawn her domestic-violence complaint.

Respondent no. 2 consented to quashing, and the State raised no serious objection.

1. Whether the High Court should quash the FIR and consequential proceedings for non-compoundable matrimonial offences where the parties have amicably settled their disputes.

2. Whether the settlement and surrounding circumstances justified exercising the High Court’s inherent jurisdiction to secure the ends of justice.

Article 226 of the Constitution and Section 528 of the BNSS (corresponding to Section 482 of the CrPC) empower the High Court to quash criminal proceedings, including for non-compoundable offences, where a genuine settlement has been reached and quashing would not adversely affect overarching public interests.

In Jitendra Raghuvanshi v. Babita Raghuvanshi, (2013) 4 SCC 58, the Supreme Court held that courts may quash proceedings involving non-compoundable offences in matrimonial disputes where the parties have amicably and voluntarily settled, notwithstanding Section 320 of the CrPC.

The Court treated the dispute as matrimonial and noted that the parties had settled their claims, the agreed settlement amount had been paid in full, the marriage stood dissolved, and the related domestic-violence complaint had been withdrawn.

Respondent no. 2 expressly had no objection to quashing, while the State raised no serious objection.

Applying the principle in Jitendra Raghuvanshi, the Court concluded that quashing was appropriate to secure the ends of justice.

The petition and pending application were disposed of.