Matrimonial criminal proceedings may be quashed under Section 482 CrPC following an amicable settlement.

The complainant, V. Vandana Kumari @ Priti, married petitioner no. 1, Manish Mishra, on 30 January 2022. She alleged that her husband, father-in-law and mother-in-law subjected her to mental and physical cruelty in connection with dowry demands and compelled her to leave the matrimonial home.

On the basis of her complaint, the Sub-Divisional Judicial Magistrate, Chapra at Saran, took cognizance on 9 November 2022 of offences under Sections 498A and 504/34 of the IPC and Section 4 of the Dowry Prohibition Act.

During the pendency of the proceedings, the parties entered into a Memorandum of Settlement dated 18 February 2024 and agreed to withdraw their respective litigations, including pursuing divorce by mutual consent under Section 13(B) of the Hindu Marriage Act.

A petition for mutual-consent divorce was subsequently filed before the Family Court, Patna, as Matrimonial Case No. 631 of 2025, which remained pending because all related proceedings had not yet been withdrawn.

Whether the High Court should exercise its inherent jurisdiction under Section 482 of the CrPC to quash criminal proceedings arising from matrimonial offences after the parties have amicably settled their dispute?

Whether the criminal proceedings and the order taking cognizance dated 9 November 2022 should be quashed to facilitate implementation of the parties’ settlement and mutual-consent divorce?

The Court exercised its inherent jurisdiction under Section 482 of the Code of Criminal Procedure 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, particularly in matrimonial disputes resolved through compromise, courts may quash criminal proceedings to bring a peaceful and final quietus to the litigation.

The Court also considered the parties’ settlement and their agreement to pursue mutual-consent divorce under Section 13(B) of the Hindu Marriage Act.

The Court noted that the dispute arose out of the matrimonial relationship and that the complainant and the petitioners had voluntarily entered into an amicable settlement covering the pending disputes.

Since the parties no longer wished to pursue the criminal case and continuation of the proceedings was obstructing the mutual-consent divorce pending before the Family Court, Patna, the Court considered that quashing would advance the ends of justice rather than serve any useful prosecutorial purpose.

Applying the principle in Mange Ram, the Court treated the settlement as a sufficient basis for exercising its inherent jurisdiction under Section 482 CrPC, without adjudicating the petitioners’ alternative contention regarding territorial jurisdiction.

It quashed the order dated 9 November 2022 passed by the Sub-Divisional Judicial Magistrate, Chapra at Saran, in Complaint Case No. 2377 of 2022, as well as all criminal proceedings arising from that complaint.

The application under Section 482 CrPC was accordingly allowed.

The parties were directed to adhere to the terms of their settlement, including withdrawal of all litigation against each other.