Matrimonial criminal proceedings quashed under Section 528 BNSS following amicable settlement of private disputes.

Respondent No. 2 (the complainant) and Petitioner No. 1 were married on February 24, 2016, and have three daughters

Following temperamental differences and separation, Respondent No. 2 initiated two sets of criminal proceedings: FIR No. 364/2021 (u/s 498A/406/34 IPC) and FIR No. 556/2020 (u/s 323/354/506/509/34 IPC) at PS Jaitpur

On December 02, 2024, the parties settled all disputes through the Mediation Centre, Saket Courts

Subsequently, a divorce by mutual consent was finalized on February 13, 2025

During the proceedings, Petitioner No. 3 (the mother-in-law) passed away

On April 04, 2025, the Joint Registrar (Judl.) verified the settlement and confirmed that the parties’ consent was voluntary and free from coercion

Whether the High Court should exercise its inherent powers to quash the FIRs and consequential criminal proceedings on the basis of a voluntary settlement in a primarily private dispute

Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (corresponding to Section 482 of the CrPC, 1973), regarding the inherent powers of the High Court

The court relied on the principle that criminal proceedings arising from private or matrimonial disputes may be quashed when a settlement is reached and continuing the prosecution would serve no useful purpose or end of justice

The court found that the dispute was essentially private in nature and did not involve any significant public interest

It noted that Respondent No. 2 appeared in person, identified by the Investigating Officer, and reiterated her "no objection" to the quashing of the FIRs following the mediation settlement and the grant of mutual consent divorce

The court reasoned that since the complainant did not wish to press charges and the parties had already settled ancillary issues such as child guardianship, the continuation of criminal proceedings would be an exercise in futility

The court also accounted for the Joint Registrar’s report, which confirmed the genuineness of the compromise deed

The court held that quashing was appropriate to secure the ends of justice under Section 528 of the BNSS

The petitioners were directed to submit original affidavits to the Trial Court within two weeks to form part of the record

Both petitions and pending applications were disposed of accordingly