Delhi High Court
Criminal Procedure and EvidenceFamily Law

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

Jatin Kumar Verma & Ors. vs The State (Govt. Of Nct Delhi) & Anr.

Delhi High CourtJUDGMENT: September 28, 20262 MIN READSOURCE JUDGMENT
Matrimonial criminal proceedings may be quashed under Section 528 BNSS following an amicable settlement.. Jatin Kumar Verma  & Ors. vs The State (Govt. Of Nct Delhi) & Anr.. Delhi High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Respondent No. 2 lodged FIR No. 0611/2021 at P.S. Ambedkar Nagar under Sections 498A/406/506/34 IPC, alleging dowry-related harassment, cruelty, assault and threats by her husband and in-laws

Source reference: pp. 1–2, para. 3

The parties, who had been living separately since 23 September 2019, settled their disputes before the Family Court Counselling Cell on 28 May 2025. They subsequently obtained a divorce, and petitioner No. 1 paid the agreed sum of ₹3,50,000 in full and final settlement

Source reference: p. 2, para. 4

In this petition under Section 528 BNSS, respondent No. 2 confirmed the voluntary settlement, receipt of the full amount and her no-objection to quashing the FIR

Source reference: p. 3, paras. 5–6
02

Issues

1. Whether the High Court should exercise its inherent powers under Section 528 BNSS to quash the FIR and consequential proceedings in light of the parties’ settlement.

Source reference: pp. 1, 3, paras. 1, 6–8

2. Whether continuation of the criminal proceedings would serve a useful purpose where the matrimonial dispute had been amicably resolved and the complainant did not wish to pursue the charges.

Source reference: p. 3, para. 7
03

Law Applied

Section 528 of the Bharatiya Nagarik Suraksha Sanhita empowers the High Court to exercise inherent jurisdiction to secure the ends of justice.

Source reference: pp. 1, 3, paras. 1, 7–8

It stated that, in the circumstances before it, quashing was appropriate where the dispute was primarily private, the parties had settled it, and the complainant no longer wished to press the charges

Source reference: pp. 1, 3, paras. 1, 7–8
04

Reasoning

The Court found that the parties had amicably resolved their matrimonial disputes, obtained a divorce, and completed payment of the settlement amount. Respondent No. 2 personally confirmed that the settlement was voluntary and that she had no objection to quashing the FIR

Source reference: pp. 2–3, paras. 4–6

Because the dispute was private in nature and the complainant did not wish to pursue the charges, the Court concluded that continuing the criminal proceedings would serve no useful purpose and that quashing would secure the ends of justice

Source reference: p. 3, paras. 7–8
05

Holding

The Court allowed the petition and quashed FIR No. 0611/2021, dated 1 November 2021, registered under Sections 498A/406/506/34 IPC, together with all consequential proceedings

It directed that the parties’ original affidavits be submitted to the Trial Court and to the concerned SHO/IO within four weeks

Source reference: pp. 3–4, para. 9

Pending applications, if any, were also disposed of

Source reference: p. 4, para. 11
06

Acts & Sections Cited

4 provisions across 2 statutes referred to in this judgment. Each provision opens on LawLens.

Bharatiya Nagarik Suraksha Sanhita, 20231

Indian Penal Code, 18603

Delhi High Court

Original Court PDF

Jatin Kumar Verma & Ors.vsThe State (Govt. Of Nct Delhi) & Anr.

Delhi High Court · September 28, 2026

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