Non-compoundable matrimonial criminal proceedings may be quashed under inherent powers after comprehensive settlement.

Respondent No. 2 lodged a complaint on 12 December 2024, leading to registration of Crime No. 125/2024 at the Shivamogga Women Police Station for offences under Sections 85, 115(2), 352 and 351(2), read with Section 3 of the Bharatiya Nyaya Sanhita, 2023, and Sections 3 and 4 of the Dowry Prohibition Act, 1961. Following investigation, a charge sheet was filed and the case was registered as C.C. No. 1088/2025.

During the proceedings, the parties settled their matrimonial disputes through mediation and agreed to dissolve their marriage by mutual consent and not pursue related proceedings, including the criminal case. A divorce decree was directed to be drawn up on 17 August 2026.

Whether criminal proceedings arising from a matrimonial dispute, including proceedings for non-compoundable offences, may be quashed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, following a settlement between the parties.

Whether, in the circumstances of this case, continuation of the criminal proceedings would serve any useful purpose or whether quashing them would secure the ends of justice.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, preserves the High Court’s inherent power to prevent abuse of the process of any court or otherwise secure the ends of justice; that power is distinct from the statutory power of compounding under Section 359 and may extend to non-compoundable offences where the circumstances justify it.

Proceedings arising predominantly from matrimonial or family disputes may be quashed on settlement if, having regard to the nature and gravity of the offences and the circumstances of the case, quashing would secure the ends of justice.

The order identifies no specific judicial precedent.

The Court found that the allegations arose from the parties’ matrimonial relationship and that their comprehensive settlement, reached through mediation, covered the criminal proceedings. The parties had agreed to dissolve their marriage, and respondent No. 2 had agreed not to pursue the case.

Considering the matrimonial origin of the dispute, the settlement and the dissolution of the marriage, the Court concluded that continuing the prosecution would serve no useful purpose and that the case warranted exercise of its inherent jurisdiction.

It quashed the proceedings in C.C. No. 1088/2025 arising from Crime No. 125/2024; the operative order describes the relief as quashing the FIR and complaint in that crime.