Non-compoundable matrimonial offences may be quashed under inherent powers after the parties amicably settle their disputes.

Petitioner No. 1 and respondent No. 2 married on 8 March 2019, separated in September 2021, and had no children.

The dispute led to FIR No. 422/2021 under Sections 498A, 406 and 34 IPC.

The parties later entered into a mediation settlement on 23 January 2026, agreed to dissolve their marriage and settle their disputes; a mutual-consent divorce decree was passed on 16 April 2026.

Of the agreed sum of ₹5,00,000, ₹3,00,000 had been paid; ₹1,75,000 was payable upon quashing this FIR and ₹25,000 upon quashing a separate FIR.

The DV Act and related execution proceedings had been withdrawn.

Respondent No. 2 confirmed that the settlement was voluntary, and the parties jointly sought quashing.

Whether the High Court could quash proceedings under Sections 498A, 406 and 34 IPC under Section 528 BNSS on the basis of a matrimonial settlement, notwithstanding the non-compoundable nature of Section 498A IPC.

Whether, in the circumstances of this case, continuation of the prosecution would serve a useful purpose or instead defeat the ends of justice.

Section 528 BNSS preserves the High Court’s inherent power to quash proceedings to secure the ends of justice or prevent abuse of process; that power is distinct from, and not confined by, the statutory compounding provisions in Section 359 BNSS (formerly Sections 482 and 320 CrPC).

Under Gian Singh v. State of Punjab, (2012) 10 SCC 303, Narinder Singh v. State of Punjab, (2014) 6 SCC 466, and Jitendra Raghuvanshi v. Babita Raghuvanshi, (2013) 4 SCC 58, matrimonial and other predominantly private disputes may be quashed after a genuine settlement, even where the offences are non-compoundable, if quashing serves the ends of justice; serious and heinous offences ordinarily do not qualify.

The Court also relied on Navneesh Aggarwal v. State of Haryana, 2025 SCC OnLine SC 1680, concerning settlement-based quashing of matrimonial prosecutions after divorce.

The Court treated the FIR as arising from a matrimonial dispute and found that the alleged offences did not fall within the category of heinous or serious offences that would preclude settlement-based quashing.

The parties had divorced by mutual consent, resolved their inter se disputes, withdrawn related proceedings, and respondent No. 2 confirmed the settlement and her consent in Court.

Although ₹2,00,000 remained payable under the settlement—₹1,75,000 upon quashing this FIR and ₹25,000 upon quashing the separate FIR—the parties undertook to abide by the settlement.

In these circumstances, the Court concluded that continuation of the prosecution would serve no fruitful purpose.

The petition, accompanying application and any other pending applications were disposed of, and the parties’ undertaking to comply with the settlement was taken on record.