High Courts may quash non-compoundable matrimonial proceedings upon a voluntary, amicable settlement.

The petitioner sought quashing of FIR No. 1020/2023, registered at P.S. Mangol Puri under Sections 498A/406/34 IPC, and the proceedings arising from it, on the basis of a settlement

The parties, whose marriage was solemnised on 21 November 2021 and who had been living separately since 21 March 2023, settled their disputes through mediation on 10 November 2025; their marriage was subsequently dissolved by mutual-consent divorce on 13 March 2026

The complainant confirmed in Court that she did not wish to pursue the matter, and the State raised no serious objection to quashing

1. Whether the High Court could quash the FIR and consequential proceedings for non-compoundable matrimonial offences under Section 528 BNSS, on the basis of the parties’ settlement

2. Whether the parties’ settlement and the circumstances of the case justified exercising that power to quash the proceedings

Section 528 BNSS preserves the High Court’s inherent power to quash criminal proceedings; the judgment also refers to Section 482 CrPC

Relying on Jitendra Raghuvanshi v. Babita Raghuvanshi, (2013) 4 SCC 58, and the principle recognised in B.S. Joshi v. State of Haryana, (2003) 4 SCC 675, the Court stated that criminal proceedings arising from matrimonial disputes may be quashed, even where the offences are non-compoundable, when the parties have amicably settled and quashing would secure the ends of justice without adversely affecting overarching public interest

The Court found that the matrimonial dispute had been finally settled through mediation, the parties’ marriage had been dissolved by mutual consent, and the complainant personally confirmed that she did not wish to pursue the case

In light of those circumstances and the State’s lack of serious objection, the Court considered the settlement sufficient to justify exercising its inherent power to quash the proceedings

The pending application was also disposed of