Matrimonial FIRs may be quashed under inherent powers after settlement where no public interest is involved.

The petitioner, Tushar Garg, married Respondent No. 2, Nikita Bansal, on 17 February 2018, and they had a son born on 2 April 2022.

The parties began residing separately from 6 May 2025 due to matrimonial incompatibility.

On Respondent No. 2’s complaint, FIR No. 693/2025 was registered at Police Station Punjabi Bagh under Sections 498A/406/34 IPC against the petitioner and his relatives.

A second FIR, FIR No. 331/2026, was registered under Sections 420/406/467/478/471 IPC read with Section 120B IPC concerning the alleged unauthorised sale of a vehicle claimed to form part of Respondent No. 2’s istridhan.

During the pendency of investigation, the parties entered into a comprehensive Settlement Agreement dated 12 July 2026 and amicably resolved all disputes.

Pursuant to the settlement, various civil and matrimonial proceedings were withdrawn, and the parties agreed to seek divorce by mutual consent.

Respondent No. 2 appeared before the Court, confirmed the settlement, and stated that she had no objection to quashing both FIRs and did not wish to pursue any criminal action.

Whether the High Court should exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 to quash FIR No. 693/2025 and FIR No. 331/2026 on the basis of an amicable settlement between the parties?

Whether continuation of the criminal proceedings would serve any useful purpose where the complainant had settled all disputes, had no objection to quashing, and the controversy was primarily private and matrimonial in nature?

The Court applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which preserves the High Court’s inherent powers to make orders necessary to give effect to any order under the Sanhita, prevent abuse of the process of court, or otherwise secure the ends of justice.

The Court further applied the principle that criminal proceedings arising from predominantly private or matrimonial disputes may be quashed on the basis of a genuine and comprehensive settlement where the complainant no longer wishes to pursue the allegations, continuation of the proceedings would serve no useful purpose, and no overriding public interest is involved.

The Court noted that the parties had comprehensively settled their matrimonial, civil, and criminal disputes, had agreed to pursue divorce by mutual consent, and had withdrawn other related proceedings.

Respondent No. 2 personally confirmed the settlement, expressly stated that she had no objection to quashing both FIRs, and waived her claims concerning the vehicle, maintenance, alimony, and istridhan, subject to the settlement terms and without prejudice to the rights of the parties’ son.

Since the disputes were primarily private in character and the complainant herself did not wish to press the allegations, the Court concluded that continuation of the criminal proceedings would not advance the administration of justice and would serve no useful purpose.

The circumstances therefore justified exercise of the Court’s inherent jurisdiction under Section 528 BNSS to secure the ends of justice.

FIR No. 693/2025 and FIR No. 331/2026, both registered at Police Station Punjabi Bagh, together with all consequential proceedings, were quashed in toto.

The parties were directed to submit the Settlement Agreement and the original affidavits to the concerned SHO/IO within four weeks.

Both petitions and the pending applications were disposed of accordingly.