The Delhi High Court has quashed a criminal case arising from a matrimonial dispute after finding that the parties had amicably settled their differences and that continuing the proceedings would serve no useful purpose. Justice Ravinder Dudeja exercised the Court’s inherent powers under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), noting that the dispute was primarily private in nature and did not involve any public interest. 61729092026CRLMM73102026_111451
The petition sought quashing of FIR No. 362/2024, registered on October 1, 2024 at Police Station Jamia Nagar, Delhi, under Sections 498A, 406 and 34 of the IPC, along with all consequential proceedings, on the basis of a compromise between the parties. 61729092026CRLMM73102026_111451
Matrimonial Dispute Led To FIR
The complainant and petitioner No. 1 were married on March 11, 2023 according to Muslim rites and customs. No child was born from the marriage.
According to the judgment, the parties began living separately from September 28, 2023 due to temperamental differences. The complainant subsequently lodged a complaint alleging persistent physical and mental harassment over dowry demands, resulting in registration of the FIR. 61729092026CRLMM73102026_111451
A charge-sheet was later filed under Sections 498A, 506, 406, 509, 354C and 34 of the IPC as well as Sections 3 and 4 of the Dowry Prohibition Act. 61729092026CRLMM73102026_111451
Parties Settled Dispute In Mediation
During the proceedings, the parties were referred to mediation and resolved their disputes before the Mediation Centre at Saket Courts, Delhi. Their settlement was recorded in writing on February 7, 2026. 61729092026CRLMM73102026_111451
Counsel for both sides informed the Court that, in terms of the settlement, petitioner No. 1 and the complainant had obtained divorce under Muslim personal law through Khula by an agreement dated March 7, 2026.
The petitioner also paid the entire agreed settlement amount of ₹1.50 lakh to the complainant. 61729092026CRLMM73102026_111451
Both sides appeared personally before the High Court and were identified by their respective counsel as well as the investigating officer from Jamia Nagar Police Station.
The complainant confirmed that the settlement had been entered into without force, fear or coercion. She also stated that she had received the entire settlement amount along with the articles and had no objection to the FIR being quashed. 61729092026CRLMM73102026_111451
Continuing Criminal Case Would Serve No Useful Purpose: Court
Taking note of the settlement and the complainant’s stand, the High Court observed:
“In view of the settlement arrived at between the parties, continuing with criminal proceedings would serve no useful purpose, especially, when dispute does not involve any public interest and is, primarily, private in nature.”
The Court further recorded that the complainant herself did not wish to press the charges against the petitioners. 61729092026CRLMM73102026_111451
It consequently held that it was appropriate to invoke the inherent powers available under Section 528 BNSS and quash the FIR.
FIR And Consequential Proceedings Quashed
The High Court quashed FIR No. 362/2024 dated October 1, 2024, registered at PS Jamia Nagar under Sections 498A, 406 and 34 IPC, together with all consequential proceedings arising from it. 61729092026CRLMM73102026_111451 61729092026CRLMM73102026_111451
The Court also directed that the original affidavits of the parties, copies of which had been placed on record before the High Court, be submitted before the Trial Court so that they become part of its record. The affidavits were also directed to be submitted to the concerned SHO/IO within four weeks.
The petition was accordingly allowed and disposed of.
Case Title: Mohd Kasim and Ors v. State of Govt. of NCT of Delhi and Anr
Case No.: CRL.M.C. 7310/2026
Bench: Justice Ravinder Dudeja
Date: September 29, 2026
