Subsequent marriage and matrimonial harmony justify quashing criminal proceedings for kidnapping and sexual offences.

Respondent No. 2 (the father of Appellant No. 2) filed an FIR on June 1, 2020, alleging that Appellant No. 1 had enticed and kidnapped his 17-year-old daughter, Appellant No. 2

Consequently, Appellant No. 1 was charge-sheeted under Sections 363, 368, and 376(2)(d) of the IPC, and Sections 5(8) and 6 of the POCSO Act

The Appellants, who are of the same religion, asserted they were in a long-term relationship and married as per Muslim rites on September 25, 2020, following which they had a child

In a statement under Section 164 of the Cr.PC, Appellant No. 2 affirmed she married of her own volition and was an adult

Appellant No. 1 moved the High Court of Uttarakhand under Section 482 of the Cr.PC to quash the proceedings, but the High Court dismissed the application on June 19, 2025, reasoning that the victim’s minority and other factual submissions required a trial

The Appellants subsequently approached the Supreme Court via a joint appeal

1. Whether criminal proceedings under the IPC and POCSO Act should be quashed when the accused and the victim have entered into a voluntary marriage and are living happily as a family

2. Whether the technicality of the victim being a minor at the time of the alleged offence necessitates the continuation of a trial despite subsequent matrimonial stability

The Court primarily exercised its inherent powers under Section 482 of the Cr.PC to prevent the abuse of the process of law and to secure the ends of justice

It relied on the principle that the "final cause of law is the welfare of society," as articulated by Benjamin N. Cardozo and adopted in K. Kirubakaran v. State of Tamil Nadu

The Court balanced the statutory rigors of the IPC (Sections 363, 376) and the POCSO Act against the substantive justice required to preserve a functional matrimonial unit

The Court reasoned that while fleeing with a minor is technically an offence under law, the overarching aim of legal proceedings is to arrive at substantive justice

It observed that the Appellants had been living in a stable matrimonial relationship for nearly six years and had a child

The Court noted that Appellant No. 2’s Section 164 statement clearly indicated her voluntary participation and happiness in the marriage

The Bench found that the High Court erred by focusing solely on the victim's age at the time of the incident while ignoring the "subsequent development" of a happy marriage

The Court emphasized that continuing criminal proceedings would constitute "painful interference" and a "burdensome" uncertainty for the couple, thereby amounting to an abuse of the legal process

Consequently, the interest of the society and the welfare of the specific family unit outweighed the need to take the criminal charges to their logical conclusion

The Court held that in the interest of rendering complete justice, the criminal case must be terminated to protect the parties’ matrimonial life

It quashed the proceedings of Criminal Case No. 10 of 2021 pending before the Court of Additional District & Sessions Judge, Haridwar, along with all incidental orders

No conditions were imposed on Appellant No. 1, with the Court expressing the earnest hope that the family would continue to live peacefully