Matrimonial FIRs may be quashed after complete settlement where the dispute is private and personal.

The petitioners sought quashing under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, of FIR No. 580/2020, registered under Sections 498A, 406, 506 and 34 of the Indian Penal Code, 1860, and Section 4 of the Dowry Prohibition Act, 1961.

Petitioner no. 1 and respondent no. 2 married in 2015, had a daughter, and had lived separately since February 2019.

The parties settled their matrimonial disputes through mediation; their mutual-consent divorce was granted on 27 January 2025, and the remaining settlement payment of Rs. 1,00,000 was paid to respondent no. 2 during the proceedings.

Respondent no. 2 confirmed the settlement and filed an affidavit stating that she had no objection to quashing the FIR.

1. Whether the High Court should exercise its inherent jurisdiction under Section 528 BNSS to quash the FIR and related proceedings arising from a matrimonial dispute that the parties have settled.

2. Whether the settlement was sufficient, in the circumstances, to warrant quashing of the proceedings.

Section 528 BNSS preserves the High Court’s inherent power to make orders necessary to secure the ends of justice or prevent abuse of the process of any court.

Applying *Gian Singh v. State of Punjab*, (2012) 10 SCC 303, the Court noted that criminal proceedings involving predominantly private or personal disputes—including matrimonial and dowry-related disputes—may be quashed where the parties have fully settled their dispute, the possibility of conviction is remote, and continuation of the proceedings would cause oppression or injustice; the nature and gravity of the offence must be considered, and serious offences affecting society are not ordinarily quashed merely on settlement.

The FIR arose from the matrimonial relationship between petitioner no. 1 and respondent no. 2. The parties had resolved their disputes through a mediated settlement, completed the mutual-consent divorce, and recorded that respondent no. 2’s custody of the minor daughter would continue.

Respondent no. 2 confirmed that the settlement was voluntary and stated that she had no objection to quashing; the balance settlement amount was also paid.

Given the private matrimonial nature of the dispute and its resolution, the Court considered quashing appropriate under the principles in *Gian Singh*.

The pending application was also disposed of.