Quashing of matrimonial FIR is permissible when parties reach an amicable settlement and no public interest is involved.

The petitioners sought the quashing of FIR No. 289/2021 registered at PS Pandav Nagar under Sections 498A/406/34 of the Indian Penal Code (IPC).

The marriage between petitioner No. 1 and respondent No. 2 (complainant) took place on December 12, 2018, but the parties separated due to temperamental differences.

During the pendency of proceedings, the husband obtained an ex-parte divorce decree.

Subsequently, the parties entered into a Settlement-cum-compromise deed dated April 18, 2026, wherein the respondent received ₹1,00,000 as full and final settlement and agreed not to challenge the divorce decree or pursue criminal charges.

Petitioner No. 3 (father-in-law) passed away during the proceedings.

1. Whether the High Court should exercise its inherent powers to quash criminal proceedings arising from matrimonial disputes when the parties have reached an amicable settlement.

The court primarily applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (formerly Section 482 CrPC), which vests inherent powers in the High Court to prevent abuse of the process of any court or to secure the ends of justice.

The court relied on the legal principle that in matters of a private nature involving matrimonial disputes, quashing is appropriate if a settlement is reached and no public interest is involved.

The Court observed that the respondent/complainant appeared in person and confirmed that the settlement was entered into voluntarily, without coercion.

The Court noted that the complainant had already received the agreed settlement amount via online transaction and expressed no further grievance.

It was reasoned that since the dispute was primarily private and matrimonial in nature, and the complainant no longer wished to press charges, continuing the criminal proceedings would serve no useful purpose and would be a futile exercise for the judicial system.

The Court also took cognizance of the fact that the trial was at a preliminary stage (appearance of accused) and that one of the original accused had since deceased.

The Court directed the parties to submit the original settlement deed and affidavits before the Trial Court within four weeks. The petition was disposed of, and the next scheduled trial date of August 4, 2026, was cancelled.