Delhi High Court: FIR Quashed After Amicable Settlement Between Parties in Matrimonial Dispute.

Headnote:

The Delhi High Court quashed FIR No. 281/2019 registered under Sections 323/354/34 IPC at P.S. Punjabi Bagh, after noting that the husband, his family members, and the complainant (wife) had amicably settled their matrimonial dispute. The Court held that when parties voluntarily resolve their differences and the continuation of proceedings would amount to abuse of process of law, it is appropriate to quash the criminal case to secure the ends of justice.

Background:

1. The FIR dated 18.05.2019 was lodged by the complainant (Respondent No. 2) against her husband and in-laws alleging physical assault, dowry harassment, and abuse when she visited her matrimonial home to inquire about her husband’s whereabouts.
2. The complaint led to registration of FIR No. 281/2019 under Sections 323 (voluntarily causing hurt), 354 (assault or criminal force to woman with intent to outrage modesty), and 34 IPC (common intention).
3. After investigation, a chargesheet was filed.
4. Subsequently, both parties entered into a Memorandum of Understanding dated 10.06.2025, whereby the petitioners agreed to pay ₹7,50,000/- as full and final settlement to the complainant.
5. The complainant confirmed before the Court that she had received the entire amount voluntarily, and had no objection to the quashing of the FIR.

Court’s Observations:

1. Justice Ravinder Dudeja observed that the dispute was matrimonial in nature, and since both parties had settled voluntarily, the continuation of criminal proceedings would serve no fruitful purpose.
2. The Court relied upon the judgments of the Supreme Court in Gian Singh v. State of Punjab (2012) 10 SCC 303 and B.S. Joshi v. State of Haryana (2003) 4 SCC 675, reiterating that:
3. The High Court can exercise inherent powers under Section 482 CrPC (now Section 528 BNSS) to quash even non-compoundable offences when the settlement is genuine and continuation of the case would amount to abuse of process of law.
4. The objective is to secure the ends of justice, not to perpetuate unnecessary litigation when the parties have reconciled.

Legal Provisions Discussed:

1. Section 528, Bharatiya Nagarik Suraksha Sanhita, 2023 (corresponding to Section 482 CrPC) – Inherent powers of High Court.
2. Sections 323, 354, 34 IPC – Offences relating to causing hurt, outraging modesty, and acts done with common intention.

Precedents:

1. Gian Singh v. State of Punjab (2012) 10 SCC 303.
2. B.S. Joshi v. State of Haryana (2003) 4 SCC 675.

Decision:

1. The Delhi High Court allowed the petition and quashed FIR No. 281/2019 dated 18.05.2019 registered at P.S. Punjabi Bagh, Delhi under Sections 323/354/34 IPC along with all consequential proceedings.
2. It held that since the matter had been settled amicably, no purpose would be served in continuing the prosecution.
3. Pending applications were also disposed of.

Result: FIR and all proceedings quashed in view of amicable settlement.

Citation: 2025:DHC:111025-2

Case: Prakash @ Prakash Chand & Ors. v. State (NCT of Delhi) & Anr.

Court: High Court of Delhi at New Delhi

Coram: Hon’ble Mr. Justice Ravinder Dudeja

Date of Decision: 10 November 2025

Crl.M.C. No.: 7877/2025