Matrimonial criminal proceedings may be quashed under Section 528 BNSS after an amicable settlement.

The petitioners—husband, mother-in-law and father-in-law—sought to quash the charge sheet in C.C. No. 54779/2024, alleging offences under Section 498A IPC and Sections 3 and 4 of the Dowry Prohibition Act

The case arose from a matrimonial dispute between the husband and respondent No. 2.

During mediation in divorce proceedings, they agreed to separate and settled their disputes.

The husband paid ₹35,00,000 towards the minor child’s welfare, and respondent No. 2 consented to quashing the criminal proceedings.

The parties also placed before the Court arrangements concerning the child, a joint bank account and a Sukanya Samriddhi account.

1. Whether the criminal proceedings under Section 498A IPC and Sections 3 and 4 of the Dowry Prohibition Act should be quashed under Section 528 BNSS in light of the parties’ settlement of their matrimonial dispute.

2. Whether continuation of those proceedings would serve any useful purpose after the parties had amicably resolved their disputes.

The Court exercised its inherent powers under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, to bring the criminal proceedings to an end in the circumstances of this matrimonial settlement.

The charge sheet alleged offences under Section 498A of the Indian Penal Code and Sections 3 and 4 of the Dowry Prohibition Act.

The judgment cites no precedent and does not set out a separate doctrinal test.

The Court considered that the complaint arose from the matrimonial relationship between the husband and respondent No. 2, that the parties had resolved their disputes and agreed to end their marriage, and that the complainant supported quashing.

Having regard to the settlement and the statements and undertakings made before it, the Court concluded that continuing the prosecution would serve no useful purpose and would cause further hardship and prejudice.

It therefore found it appropriate to exercise its Section 528 BNSS powers.