Criminal proceedings can be quashed on the basis of a compromise in matrimonial disputes if it serves the ends of justice.

ORDER

This Criminal Original Petition is filed under Section 482 CrPC / Section

528 BNSS, seeking to quash the FIR in Crime No.13 of 2023 on the file of the

1^st respondent.

2. The gist of the allegations in the FIR is that the accused persons assaulted the defacto complainant and had driven out of the matrimonial home and also demanded dowry. Pursuant to the complaint given by the defacto complainant / second respondent, a case in Crime No.13 of 2023 was registered on the file of the first respondent against the petitioners for the offences under Sections 498(A), 406 & 323 of IPC and Section 4 of the Dowry Prohibition Act, 1961. Seeking quashment of the FIR, this Criminal Original Petition is filed.

3. Admittedly, the petitioners and the second respondent are relatives, and they have now resolved the dispute amicably. A Joint Compromise Memo dated 25.02.2026 has been filed before this Court.

4. The petitioners and the second respondent / defacto complainant are present before this Court in person and are identified by Mr.S.Chitra, STR, AWPS, All Women Police Station, Sattur, Virudhunagar District. The defacto complainant has categorically stated that she does not wish to pursue the proceedings against the petitioners herein. This Court is satisfied that the compromise is voluntary and not the result of any coercion or undue influence.

5. The law relating to quashment of criminal proceedings on the basis of compromise between the parties is well settled. In Gian Singh v. State of Punjab¹, the Hon’ble Supreme Court authoritatively held that the inherent power of the High Court under Section 482 CrPC is of wide amplitude and may be exercised to quash criminal proceedings even in respect of non- compoundable offences, provided the dispute is essentially private in nature and the quashment would secure the ends of justice. The Court, however, drew a clear distinction between offences arising out of personal or matrimonial disputes, commercial transactions and similar private wrongs, and serious or heinous offences having grave impact on society, holding that the latter category cannot ordinarily be quashed merely on the basis of a settlement. 6. The said principles were succinctly crystallised in Parbatbhai Aahir v. State of Gujarat², wherein the Supreme Court, after surveying the

1 2012 (10) SCC 303 2 2017 (9) SCC 641 earlier precedents, laid down broad propositions governing the exercise of inherent jurisdiction on the basis of compromise. It was emphasised that the paramount consideration is whether the continuance of the criminal proceedings would be unfair or contrary to the interests of justice, and whether the dispute predominantly bears a civil or private character, rendering the possibility of conviction remote and bleak.

7. In State of Madhya Pradesh v. Laxmi Narayan³, the Supreme Court reiterated and clarified the limitations on such power, holding that offences of a serious nature, particularly those involving mental depravity, grave violence, or offences against society at large, cannot be quashed on the basis of compromise, even if the parties have amicably settled the dispute. The Court further cautioned that while examining compromise quash petitions, the High Court must consider the nature and gravity of the offence, the conduct of the accused, and the stage of the proceedings, and the overall impact on society and must satisfy itself that the settlement is voluntary and not the result of coercion or undue influence.

8. Applying the aforesaid principles to the facts of the present case, this Court has carefully examined the nature and gravity of the allegations, the

3 2019 (5) SCC 688 relationship between the parties, the conduct of the petitioners, the stage of the proceedings, and the voluntary nature of the c