Inherent powers permit quashing of a Section 69 BNS FIR after voluntary marriage and settlement.

The petitioners sought quashing of FIR No. 245/2026 dated 22 July 2026, registered at Police Station Laxmi Nagar under Section 69 of the Bharatiya Nyaya Sanhita, 2023 (“BNS”), along with all consequential proceedings, on the basis of a settlement between the parties.

Respondent No. 2 had alleged that she was in a physical relationship with Petitioner No. 1 on the promise of marriage, but that he subsequently refused to marry her; allegations of threats, defamation and intimidation were also made against Petitioner Nos. 2 and 3.

No charge-sheet had been filed.

During the proceedings, Respondent No. 2 stated that she had voluntarily married Petitioner No. 1 on 19 August 2026 at an Arya Samaj Mandir and had no subsisting grievance or objection to quashing of the FIR.

She further stated that the FIR had been lodged in haste due to a misunderstanding regarding Petitioner No. 1’s intention to marry her and that she was living happily with him after the marriage.

Whether the High Court should exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (“BNSS”) to quash an FIR alleging an offence under Section 69 BNS where the complainant and the accused have subsequently married and amicably settled their dispute?

Whether continuation of the criminal proceedings, despite the complainant’s voluntary settlement and express lack of objection, would serve any useful purpose or would instead prejudice the parties’ matrimonial life?

The Court exercised its inherent powers under Section 528 BNSS to secure the ends of justice and prevent abuse of the process of court.

It applied the principle recognised in Gian Singh v. State of Punjab & Anr., (2012) 10 SCC 303, that criminal proceedings may be quashed in appropriate cases involving a genuine settlement where continuation of the proceedings would serve no useful purpose, particularly when the dispute is essentially personal in nature.

The Court also relied on its decisions in Abu Bakar v. State NCT of Delhi & Anr., W.P.(CRL.) 782/2024, order dated 12 March 2024, Parmanand Mishra & Anr. v. State NCT of Delhi & Anr., CRL.M.C. 3076/2021, decided on 5 August 2022, and Vikas Kumar & Ors. v. State & Anr., CRL.M.C. 1054/2021, decided on 11 January 2022, where proceedings arising from allegations of sexual relations on the promise of marriage were quashed after the parties settled and married.

The Court noted that the complainant was present in person, had married Petitioner No. 1 voluntarily and with her full consent, and had expressly stated that she had not been threatened, induced or pressured into the marriage.

Since she had confirmed that the FIR arose from a misunderstanding, that she was living happily with Petitioner No. 1, and that she had no objection to quashing, the dispute had been amicably resolved.

Applying the principles governing exercise of inherent jurisdiction under Section 528 BNSS and the settlement-based quashing recognised in Gian Singh and the cited Delhi High Court decisions, the Court concluded that continuation of the prosecution would serve no useful purpose and could adversely affect the parties’ matrimonial life.

Accordingly, FIR No. 245/2026 dated 22 July 2026, registered at Police Station Laxmi Nagar under Section 69 BNS, together with all consequential proceedings, was quashed in exercise of the Court’s inherent powers under Section 528 BNSS.

The parties were directed to submit the original affidavits before the concerned Investigating Officer/Station House Officer within two weeks; the petition and pending applications were disposed of.