Settlement of matrimonial disputes justifies quashing criminal proceedings to prevent abuse of process and secure justice.

The petitioners (husband and in-laws) sought the quashing of an FIR and criminal proceedings arising from Giridih Mufassil P.S. Case No. 308 of 2020. The case was registered for offences under Sections 498A (cruelty) and 494 (marrying again during lifetime of husband or wife) of the Indian Penal Code, and Sections 3/4 of the Dowry Prohibition Act

While the investigation was ongoing and before a charge-sheet was submitted, the parties filed a joint compromise petition (I.A. No. 6685 of 2026) stating they had settled their matrimonial disputes

1. Whether the High Court should exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 to quash criminal proceedings involving non-compoundable matrimonial offences on the basis of a settlement between the parties

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (corresponding to Section 482 of the Cr.P.C.), which saves the inherent power of the High Court to prevent abuse of the process of law or to secure the ends of justice

The rule dictates that while serious offences against society cannot be quashed via compromise, matrimonial disputes with an "overwhelmingly civil flavour" may be quashed if a settlement renders the chance of conviction remote and continuation would result in extreme injustice, as established in Parbatbhai Aahir @ Parbatbhai Bhimsinhbhai Karmur & Others vs. State of Gujarat & Another (2017) 9 SCC 641

The Court observed that the dispute was essentially private, arising from matrimonial disharmony, and lacked the "mental depravity" associated with heinous crimes like murder or rape

By examining the joint compromise petition, the Court determined that because the victim and the accused had fully resolved their grievances, the possibility of a successful prosecution was "remote and bleak"

The Court reasoned that forcing the parties to continue with the criminal trial despite their settlement would constitute an abuse of the judicial process and cause undue oppression to the petitioners

The Court allowed the petition and quashed the entire criminal proceeding including the FIR in connection with Giridih Mufassil P.S. Case No. 308 of 2020. Interlocutory Application No. 6685 of 2026 was also disposed of accordingly