Non-compoundable matrimonial FIR quashed under inherent powers of BNSS following amicable settlement between parties.

The petitioners filed a petition to quash FIR No. 237/2022, registered at PS Mansarovar Park under Sections 498A/406/34 of the IPC, following a matrimonial dispute

The marriage between Petitioner No. 1 and Respondent No. 2 was solemnized on April 25, 2021, but the parties separated shortly thereafter due to temperamental differences

Although the charge sheet added serious offences under Sections 313, 377, and 506 of the IPC and Section 4 of the Dowry Prohibition Act, the parties reached an amicable settlement via the Delhi Mediation Centre on March 5, 2025

Under the settlement, the parties obtained a divorce by mutual consent on January 19, 2026, and Respondent No. 2 received a total of Rs. 5.5 lakhs as full and final alimony

Respondent No. 2 appeared in court, confirmed the settlement, and stated she had no objection to the quashing of the FIR

Whether the High Court should exercise its inherent powers to quash criminal proceedings involving non-compoundable offences on the basis of a matrimonial settlement

The court primarily applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which preserves the inherent powers of the High Court to secure the ends of justice

It relied on the landmark precedents of Gian Singh v. State of Punjab (2012) and Narinder Singh v. State of Punjab (2014), which established that proceedings in non-compoundable cases can be quashed if the dispute is overwhelmingly private or matrimonial in nature, a settlement is reached, and the prospect of conviction remains remote and bleak

The court noted that while the charge sheet included allegations under Sections 313 and 377 of the IPC, the complainant herself admitted the FIR was primarily a result of temperamental differences and that she wished to move on with her life

The court reasoned that since the parties had already dissolved their marriage and settled all financial claims, the dispute remained private and did not involve public interest

Applying the standards from Narinder Singh, the court found that continuing the prosecution would serve no meaningful purpose as the complainant was no longer willing to support the prosecution, rendering the possibility of conviction remote

The court quashed FIR No. 237/2022 and all consequential proceedings arising therefrom

It further directed the parties to submit original affidavits to the concerned SHO/IO within two weeks to finalize the closure