Matrimonial Criminal Proceedings Quashed Following Settlement and Full Satisfaction of Financial and Property Obligations.

The petitioners (the husband and his family) sought the quashing of FIR No. 296/2021 registered at P.S. Saket for offences under Sections 498A/406/34 IPC.

The marriage, solemnized in 2005, resulted in two children but later fractured due to temperamental differences, leading to separate living arrangements and criminal litigation.

During proceedings under the PWDVA, 2005, the parties reached a settlement through the Mediation Centre, Saket Courts.

They obtained a divorce by mutual consent on March 28, 2026.

The settlement involved a total payment of Rs. 2,00,00,000, with specific allocations for the wife and both children.

On the date of the hearing, the balance payment was handed over via Demand Drafts, and the wife handed over possession of the matrimonial home to her brother-in-law as agreed.

1. Whether the High Court should exercise its inherent powers to quash the FIR and consequential proceedings based on a voluntary settlement in a matrimonial dispute.

2. Whether continuing criminal proceedings would serve any useful purpose given the private nature of the dispute and the amicable resolution reached by the parties.

The Court exercised its inherent powers under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (formerly Section 482 of the CrPC) to quash criminal proceedings to secure the ends of justice.

The court relied on the principle that in disputes of a primarily private or matrimonial nature, where parties have settled all grievances and the complainant no longer wishes to prosecute, the High Court may quash proceedings if they serve no public interest.

The Court observed that the parties had resolved all pending disputes, including the withdrawal of other related cases, under the aegis of the Mediation Centre.

It verified the authenticity of the settlement by interacting with Respondent No. 2, who was present in person and confirmed that she had entered the agreement of her own free will without coercion.

The Court noted that the terms of the settlement—including the payment of alimony and maintenance (Rs. 2 Crores), custody arrangements, and the return of property—had been substantially complied with.

The Court reasoned that since the dispute was private and the complainant expressed "no objection" to quashing the FIR, continuing the trial would be a futile exercise and a waste of judicial time.

The holding was made subject to the petitioners depositing a cost of Rs. 25,000 into the NDBA Members Welfare Fund within four weeks.

The Court directed that proof of deposit and the original settlement documents be submitted to the Trial Court to finalize the matter.