Inherent powers permit quashing rape proceedings where the parties subsequently marry to secure the ends of justice.

The Petitioner and Respondent No. 2 met in late 2022 during a train journey and developed a friendship

Respondent No. 2 alleged that in December 2022, the Petitioner established physical relations with her on the pretext of marriage, but later claimed he would only marry as per his parents' choice

This led to the registration of FIR No. 267/2023 on April 26, 2023, under Section 376(2)(n) of the IPC

Following the filing of the charge-sheet and the framing of charges, the parties reached an amicable settlement and entered into a legal marriage on January 7, 2026

Respondent No. 2 appeared before the Court, stating the FIR resulted from a "miscommunication" and that she was now living happily with the Petitioner

1. Whether the High Court should exercise its inherent power to quash criminal proceedings for a non-compoundable and grave offence under Section 376(2)(n) IPC based on a subsequent marriage and settlement between the parties

2. Whether continuing the criminal proceedings would serve any meaningful purpose when the prosecutrix and the accused have settled their matrimonial life

The Court primarily applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (corresponding to Section 482 of the CrPC), which saves the inherent power of the High Court to prevent abuse of process or secure the ends of justice

It relied on the principles established in Narinder Singh & Ors. v. State of Punjab & Anr. (2014), which allows quashing of non-compoundable cases if the court is satisfied that the scope of conviction is remote and bleak

The Court further cited Madhukar & Anr. v. State of Maharashtra (2025), noting that while Section 376 IPC is heinous, quashing is permissible to secure justice based on the specific facts of a case

Alongside local precedents like Abu Bakar v. State NCT of Delhi (2024)

The Court observed that while rape is a grave offence, the specific context of this case—a relationship premised on a promise of marriage—altered the necessity of trial

Upon interacting with the parties in chambers, the Court verified that Respondent No. 2 was a law student who voluntarily entered the settlement and marriage without coercion

The Court reasoned that since the parties are now legally married and residing together, the "real purpose" of the criminal proceedings has been exhausted

It determined that the consistent stance of the complainant indicated she would not support the prosecution, rendering the possibility of conviction remote

Consequently, following the doctrine of "securing the ends of justice," the Court found that quashing the FIR was necessary to protect the matrimonial harmony of the parties

It held that in light of the subsequent marriage and the happy cohabitation of the parties, continuing the prosecution would be a futile exercise

The Court directed that the original affidavit of Respondent No. 2 be handed over to the Investigating Officer and disposed of all pending applications