Uttarakhand HC quashes dowry-death FIR after deceased woman’s father settles case, attributes death to medical complications

Respondent no. 3, the father of the deceased, alleged that his daughter’s marriage with petitioner no. 1 was solemnized on 22 April 2023 and that, thereafter, she was subjected to dowry-related cruelty by the petitioners.

He further alleged that, after prenatal sex determination revealed a female foetus, the deceased’s pregnancy was terminated at the petitioners’ instance, following which her health deteriorated and she was not provided adequate medical treatment.

The deceased died on 11 July 2025. On the complaint of respondent no. 3, FIR No. 0308 of 2025 was registered at Police Station Transit Camp, District Udham Singh Nagar, under Section 80 of the Bharatiya Nyaya Sanhita, 2023.

During the proceedings, the parties filed a jointly signed compounding application supported by affidavits and informed the Court that they had amicably settled the dispute.

Whether the High Court should exercise its jurisdiction to quash FIR No. 0308 of 2025 and the proceedings arising from it on the basis of an amicable settlement between the accused and the deceased’s father

Whether, in view of the settlement, the continuation of proceedings under Section 80 of the Bharatiya Nyaya Sanhita, 2023, would constitute an abuse of the process of law when the possibility of conviction is remote and bleak

The Court considered the offence under Section 80 of the Bharatiya Nyaya Sanhita, 2023, and applied the principles governing quashing of criminal proceedings on the basis of a settlement as laid down by the Supreme Court in Gian Singh v. State of Punjab, (2012) 10 SCC 303, and Narinder Singh v. State of Punjab, (2014) 6 SCC 466.

These authorities recognise that, in appropriate cases, the High Court may quash criminal proceedings where the dispute has been genuinely settled, the likelihood of conviction is remote, and continuation of the prosecution would cause oppression, prejudice or injustice and amount to abuse of the process of law.

The Court took note of the parties’ voluntary settlement, their personal appearance or verified participation through video conferencing, and respondent no. 3’s clear statement that he did not wish to pursue the criminal case.

Applying the principles in Gian Singh and Narinder Singh, the Court concluded that the settlement materially reduced the possibility of a successful prosecution and that the likelihood of conviction was remote and bleak.

In those circumstances, continuation of the criminal proceedings would cause oppression and prejudice to the petitioners and would amount to an abuse of the process of law.

The compounding application, I.A. No. 1 of 2026, was consequently disposed of.