Matrimonial criminal proceedings may be quashed under Section 482 CrPC after genuine settlement and mutual-consent divorce.

Opposite Party No. 2 alleged that she married Petitioner No. 1 in 2007 and was thereafter subjected to mental and physical cruelty by the petitioners in connection with a demand for a Scorpio car. She further alleged an attempt to burn her, forced miscarriage in 2020, and theft at her parental home

On these allegations, Balia P.S. Case No. 334 of 2023 was registered under Sections 341, 323, 504, 506, 379, 307 and 498A of the IPC and Sections 3/4 of the Dowry Prohibition Act, 1961

Subsequently, the parties settled their disputes; the petitioners paid ₹10 lakhs to Opposite Party No. 2 as full and final settlement, and the parties obtained a mutual-consent divorce in Divorce Case No. 94 of 2024

Opposite Party No. 2 supported the compromise and expressly stated that she had no objection to quashing the criminal proceedings

Whether the High Court should exercise its inherent jurisdiction under Section 482 of the Cr.P.C. to quash criminal proceedings arising from a matrimonial dispute after the parties have entered into a compromise and obtained a mutual-consent divorce?

Whether continuation of the FIR and prosecution would serve any legitimate purpose in view of the full and final settlement and the consent of the complainant to quashing?

The Court considered the offences alleged under Sections 341, 323, 504, 506, 379, 307 and 498A of the IPC and Sections 3/4 of the Dowry Prohibition Act, 1961

It applied the inherent jurisdiction under Section 482 of the Cr.P.C. to prevent abuse of the process of court and secure the ends of justice.

Relying on Mange Ram v. State of Madhya Pradesh & Anr., 2025 SCC OnLine SC 1681, the Court held that criminal proceedings arising principally out of matrimonial disputes may be quashed where the parties have genuinely compromised their dispute, particularly when the settlement has brought the matrimonial litigation to an end

The Court treated the dispute as having been resolved through a genuine and comprehensive settlement. The parties had obtained a mutual-consent divorce, the petitioners had paid ₹10 lakhs towards full and final settlement, and the complainant supported quashing of the proceedings

Applying the principle in Mange Ram, the Court concluded that continuation of the prosecution, despite the settlement and termination of the matrimonial relationship, would unnecessarily consume judicial time and would not advance any useful or legitimate purpose

The Court therefore found it appropriate to exercise its inherent powers under Section 482 of the Cr.P.C.

The proceedings were terminated on the basis of the parties’ compromise, mutual-consent divorce, full and final settlement, and the complainant’s consent to quashing