Non-compoundable matrimonial proceedings may be quashed after the settlement is fully performed.

The petitioners sought quashing of FIR No. 0560/2018, registered at Police Station Shakarpur under Sections 498A, 406 and 34 of the Indian Penal Code, 1860, arising from the matrimonial relationship between petitioner no. 1 and respondent no. 2.

They entered into a settlement deed dated 5 October 2024, providing for payment of ₹10,00,000 to respondent no. 2 in two instalments.

Respondent no. 2 confirmed before the Court, after identification by the Investigating Officer, that she had received the agreed amount and had no surviving claims against the petitioners.

Petitioner no. 2 had died during the proceedings; petitioners nos. 1 and 3 were present and identified by the Investigating Officer.

1. Whether the FIR and proceedings arising from it could be quashed on the basis of the settlement between petitioner no. 1 and respondent no. 2.

2. Whether the settlement and respondent no. 2’s confirmation that she had received the agreed amount and had no surviving claims supported granting the joint request to quash.

The Court relied on Gian Singh v. State of Punjab, (2012) 10 SCC 303, and Narinder Singh v. State of Punjab, (2014) 6 SCC 466, as the governing authorities on quashing criminal proceedings in light of a settlement.

The offences alleged were under Sections 498A, 406 and 34 IPC.

The Court treated the dispute as arising from the matrimonial relationship between petitioner no. 1 and respondent no. 2 and considered the parties’ settlement, including payment of the full agreed sum of ₹10,00,000.

Respondent no. 2 confirmed receipt of the amount and that she had no surviving claims; the Court also noted the presence and identification of the appearing petitioners.

In light of these circumstances and the cited Supreme Court decisions, the Court found no impediment to quashing the FIR and consequential proceedings.