Delhi High Court Quashes FIR in Matrimonial Dispute Following Amicable Settlement.

Headnote:

The Delhi High Court quashed an FIR registered under Sections 498A, 406, and 34 of the Indian Penal Code after the parties amicably settled their matrimonial dispute. The Court observed that since the settlement was voluntary and all terms were fulfilled, continuation of criminal proceedings would serve no purpose and amount to abuse of the process of law. The judgment reinforces the principle that matrimonial cases, once resolved amicably, should be brought to a peaceful conclusion through exercise of the Court’s inherent powers.

Background:

• The petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 sought quashing of FIR No. 190/2021, dated 21.04.2021, registered at P.S. Chhawla, District Dwarka, under Sections 498A/406/34 IPC.

• The marriage between Petitioner No.1 (husband) and Respondent No.2 (wife) was solemnized on 12.03.2018, and they began living separately on 25.05.2020 due to temperamental differences.

• The FIR alleged harassment and dowry-related cruelty by the husband and his family members. A chargesheet was filed against all petitioners.

• Subsequently, the parties resolved their disputes before the Counselling Cell, Dwarka Courts, through a Settlement Agreement dated 21.01.2025.

• Pursuant to the settlement, the parties obtained divorce on 04.06.2025, and the husband paid ₹6,00,000 along with istridhan articles to the wife as full and final settlement.

Court’s Observations:

• Both parties were present before the Court and confirmed that the settlement was voluntary, without any coercion, fear, or undue influence.

• The Court referred to precedents including Gian Singh v. State of Punjab [(2012) 10 SCC 303], Jitendra Raghuvanshi v. Babita Raghuvanshi [(2013) 4 SCC 58], and B.S. Joshi v. State of Haryana [(2003) 4 SCC 675], wherein the Supreme Court held that matrimonial disputes settled amicably should not be allowed to fester through criminal prosecution.

• The Court reiterated that inherent powers under Section 482 CrPC (now Section 528 BNSS) can be invoked to prevent abuse of judicial process and secure the ends of justice.

• Since the dispute was purely matrimonial and all settlement terms were fulfilled, further prosecution would serve no legitimate purpose.

Decision:

The Delhi High Court allowed the petition and quashed FIR No. 190/2021 dated 21.04.2021, registered at P.S. Chhawla, along with all proceedings arising therefrom. Pending applications, if any, were also disposed of.

Legal Provisions Discussed:

• Section 528, Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) – Inherent powers of the High Court to prevent abuse of process and secure justice.

• Sections 498A, 406 & 34, Indian Penal Code, 1860 – Cruelty by husband or relatives; criminal breach of trust; acts done by several persons in furtherance of common intention.

• Precedents: Gian Singh v. State of Punjab (2012) 10 SCC 303; B.S. Joshi v. State of Haryana (2003) 4 SCC 675; Jitendra Raghuvanshi v. Babita Raghuvanshi (2013) 4 SCC 58.

Citation: 2025:DHC:CRLMC:7672

Case: Vikas & 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: 31 October 2025

Case No.: CRL.M.C. 7672/2025