Matrimonial disputes resolved by settlement may be quashed to prevent abuse of the process of law.

The Applicant, Pankaj Sharma, filed an application under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, seeking to quash the charge-sheet dated 14.03.2021 and the cognizance order dated 31.05.2025 regarding Criminal Case No. 3138 of 2021.

The case involved allegations under Sections 323, 504, and 498-A of the IPC and Sections 3/4 of the Dowry Prohibition Act.

During the proceedings, the parties filed a Joint Compounding Application (I.A. No. 01 of 2026), asserting that the matrimonial dispute had been amicably settled through mutual agreement.

Both parties appeared in person before the Court to confirm the settlement.

1. Whether the High Court should exercise its inherent powers to quash criminal proceedings involving non-compoundable matrimonial offences based on an amicable settlement between the parties.

The Court exercised its inherent powers under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (which corresponds to Section 482 of the CrPC).

In cases which are predominantly matrimonial or personal in nature, the High Court possesses the authority to quash proceedings to prevent the abuse of the process of law, even if some offences are technically non-compoundable under the general criminal statutes.

The Court observed that while the State Counsel opposed the compounding on the grounds that certain offences were non-compoundable, the core of the dispute was matrimonial and personal.

Upon interacting with both the Applicant and Respondent No. 2, the Court verified that they had resolved their grievances and no longer wished to pursue the litigation.

The Court reasoned that since the parties had settled, the likelihood of conviction was remote, and continuing the criminal trial would serve no "fruitful purpose," effectively wasting judicial time and constituting an abuse of legal process.

The Court allowed the Compounding Application (I.A. No. 01 of 2026) and quashed the entire proceedings of Criminal Case No. 3138 of 2021, including the charge-sheet and cognizance order, qua the Applicant. The Criminal Miscellaneous Application was accordingly disposed of.