1. Matrimonial dispute — Settlement agreement — Divorce decree under Section 13B, Hindu Marriage Act, 1955 — Pending maintenance application and criminal proceedings. (Para 2 , 3 , 4 )
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2025 Supreme(SC) 189
SUPREME COURT OF INDIA
ABHAY S. OKA, UJJAL BHUYAN, JJ.
Vandna Rani - Appellant
Versus
Sandeep Popli - Respondent
Criminal Appeal No(s).89 of 2025 (ARISING OUT OF S.L.P. (CRIMINAL) NO(S).8599/2024)
Decided on : 07-01-2025
Advocates:
Advocate Appeared:
For the Appellant : Mr. Madhav Sinhal, Adv., Mr. Rahul Khurana, AOR
For the Respondent: Mr. Jairaj Singh, Adv., Mr. Vaibhav Niti, AOR, Mr. Divyanshu Agrawal, Adv., Ms. Madhavi Agrawal, Adv.
Advocate Appeared:
For the Appellant : Mr. Madhav Sinhal, Adv., Mr. Rahul Khurana, AOR
For the Respondent: Mr. Jairaj Singh, Adv., Mr. Vaibhav Niti, AOR, Mr. Divyanshu Agrawal, Adv., Ms. Madhavi Agrawal, Adv.
Settlement agreements in matrimonial disputes can lead to the quashing of pending legal proceedings when terms are fulfilled.
Headnote:(A) Hindu Marriage Act, 1955 - Section 13B - Settlement Agreement dated 1st October, 2024 - Parties complied with the main condition of settlement regarding payment of Rs.19,00,000/- - Decree of divorce granted under Section 13B - Pending proceedings quashed in light of settlement. (Paras 3, 5)
(B) Mediation - Role of mediator appreciated for facilitating resolution of matrimonial dispute. (Paras 6)
Facts of the case:
The appellant and respondent reached a settlement agreement, leading to the dissolution of marriage and compliance with financial terms. (Para 3)
Findings of Court:
The court disposed of the maintenance application and quashed the FIR based on the settlement. (Para 5)
Issues: The main issue was the compliance with the settlement agreement and the subsequent quashing of pending proceedings. (Para 4)
Ratio Decidendi: The court emphasized the importance of settlement in matrimonial disputes and acknowledged the mediator's role in resolving the matter amicably. (Para 6)
Result: Appeal disposed of.
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2. The court observed that settlement terms were complied with and a divorce decree was passed, necessitating the quashing of pending proceedings to resolve the dispute. (Para 3 , 4 )
3. Pending matrimonial and criminal proceedings may be quashed upon the execution of a settlement agreement and the granting of a divorce decree. (Para 3 , 4 , 5 )
4. Maintenance application disposed of and FIR along with related proceedings quashed. (Para 5 )
5. Can a settlement agreement lead to the quashing of an FIR and disposal of maintenance applications in matrimonial disputes?
Yes, when parties reach a settlement, comply with its financial terms, and obtain a decree of divorce under the Hindu Marriage Act, the court may quash pending criminal proceedings and dispose of maintenance applications. (Para 3 , 4 , 5 )
ORDER :
1. Leave granted.
2. A Settlement Agreement dated 1st October, 2024 duly signed by the appellant, her son, the respondent and their respective learned counsel, is placed on record. The Settlement Agreement is also signed by the learned Mediator appointed by the Supreme Court Mediation Centre.
3. It is an admitted position that the main condition of settlement regarding the payment of a sum of Rs.19,00,000/-(Rupees Nineteen Lakh) by the respondent to the appellant has been complied with. In fact, it is an accepted position that in terms of the settlement, the parties applied for dissolution of marriage before the competent Court and a decree of divorce under Section 13B of the Hindu Marriage Act, 1955 has been passed.
4. What remains is the quashing of the pending proceedings between the parties.
5. Accordingly, we pass the following order:
(i) Maintenance Application No.105/2019 pending before the Family Court at Sirsa, Haryana, is disposed of in the light of the settlement; and
(ii) FIR No.1127 dated 13th November, 2018 registered at Police Station – City Sirsa and the proceedings initiated on the basis of the same are hereby quashed in the light of the settlement.
6. We record our appreciation for the reasonable stand taken by the parties as well as by their respective learned counsel for putting an end to the matrimonial dispute. The role played by the learned Mediator is also appreciated.
7. The Appeal is, accordingly, disposed of.
