Matrimonial criminal proceedings against in-laws may be quashed under Section 482 CrPC following amicable settlement.

The petitioner, Shobha Devi, was an accused in Kotwali P.S. Case No. 356 of 2017, arising from allegations by opposite party no. 2 that she and other members of her matrimonial family subjected her to cruelty and made dowry-related demands.

Following investigation, a charge-sheet was submitted and the Chief Judicial Magistrate, Gaya, took cognizance on 2 August 2019 of offences under Sections 498A and 406 read with Section 34 of the Indian Penal Code, and Sections 3 and 4 of the Dowry Prohibition Act against the petitioner and others.

During the pendency of the proceedings, the matrimonial dispute was settled through a memorandum of settlement dated 3 December 2025 and a joint compromise petition dated 9 February 2026.

Under the settlement, the husband agreed to pay ₹25,00,000 to opposite party no. 2, with the parties agreeing to seek dissolution of their marriage by mutual consent under Section 13B of the Hindu Marriage Act; the demand draft was deposited before the Family Court, Gaya.

Opposite party no. 2 did not dispute the settlement and did not oppose quashing of the proceedings against the petitioner.

Whether the criminal proceedings arising from a matrimonial and dowry dispute should be quashed under the Court’s inherent jurisdiction under Section 482 Cr.P.C. after the parties have entered into an amicable settlement?

Whether the proceedings against the petitioner, a relative of the husband, should be quashed where the matrimonial dispute has been settled and continuation of the prosecution would serve no useful purpose?

The Court considered the offences under Sections 498A and 406 read with Section 34 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act, and exercised its inherent jurisdiction under Section 482 Cr.P.C. to prevent abuse of the process of court and secure the ends of justice.

It relied on Kahkashan Kausar @ Sonam v. State of Bihar, (2022) 6 SCC 599, for the principle that relatives of the husband should not be unnecessarily implicated in matrimonial prosecutions through general or omnibus allegations, since even eventual acquittal may leave lasting prejudice.

It also relied on Mange Ram v. State of Madhya Pradesh & Anr., 2025 SCC OnLine SC 1681, for the principle that, particularly in matrimonial-dispute cases, the High Court may quash criminal proceedings under Section 482 Cr.P.C. when the parties have genuinely compromised their dispute and continuation of the prosecution would not advance the interests of justice.

The Court found that the prosecution arose out of matrimonial discord between opposite party no. 2 and her husband and that the dispute had subsequently been resolved through a written settlement, including payment of ₹25,00,000 and proposed dissolution of the marriage by mutual consent.

Since opposite party no. 2 accepted the settlement and expressly did not oppose the petition, the Court considered that continuation of the criminal case would serve no meaningful purpose and would perpetuate a dispute that had already been amicably resolved.

Applying the principles in Kahkashan Kausar concerning the unwarranted implication of matrimonial relatives and Mange Ram concerning quashing after settlement, the Court held that there was no justification for continuing the prosecution against the petitioner.

The Court also took note of its earlier order quashing the proceedings against co-accused Ramesh Prasad on the basis of the same settlement.

Accordingly, the cognizance order dated 2 August 2019 passed by the Chief Judicial Magistrate, Gaya, in Kotwali P.S. Case No. 356 of 2017 was quashed insofar as it related to the petitioner, and the application under Section 482 Cr.P.C. was allowed.