Allowed¶20

Sanjeev and 2 Others v. State of U.P. and Another

Allahabad HC8 Sept 2025NA528/19984/2025

Case brief

AI extract

What is this about?

Quashing of criminal proceedings in a matrimonial dispute under Sections 498A, 323, 504, 506 IPC and Sections 3/4 DP Act after court-verified compromise dated 15.7.2025 (verified 5.8.2025); application under Section 528 BNSS allowed; abuse of process of law; trial an exercise in futility; relied on Parbatbhai Aahir (2017) 9 SCC 641, Gian Singh (2012) 10 SCC 303, State of M.P. v. Laxmi Narayan (2019) 5 SCC 688; Case Crime No. 154 of 2023, P.S. Falavda, District Meerut; Allahabad High Court; Vikram D. Chauhan, J.; decided September 9, 2025.

What did the court decide?

Quashing of charge sheet no. 01 dated 21.11.2023, the cognizance order dated 06.12.2024 and the entire proceedings of Case Crime No. 154 of 2023 (State Vs. Sanjeev & others), pending in the court of Additional Civil Judge (J.D.) IIIrd Meerut. ¶20

Sanjeev and 2 Others Vs State of U.P. and Another — Dowry and Cruelty | Allahabad HC (2025)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the entire proceedings pursuant to charge sheet no. 01 dated 21.11.2023 and the cognizance order dated 06.12.2024 in Case Crime No. 154 of 2023 (under Sections 498A, 323, 504, 506 I.P.C. and Section 3/4 D.P. Act) should be quashed. +1 more

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Court's answer

In view of the well-settled principles of law laid down by the Hon'ble Apex Court in Parbatbhai Aahir, Gian Singh and State of M.P. v. Laxmi Narayan, the proceedings of Case Crime No. 154 of 2023 are quashed.

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Ratio / Principle

The criminal proceedings in the present case had essentially been an outcome of a matrimonial dispute and there were no overbearing circumstances warranting prosecution of the applicants after the parties entered into a settlement.

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Key takeaways

In view of the parties' settlement there was practically no chance of recording conviction even if the case went to trial; the entire trial would be an exercise in futility, and quashing the criminal proceedings would be in the interest of justice.ratio¶16
Continuation of the criminal proceeding despite the settlement and compromise between the victim and the wrongdoer would tantamount to abuse of process of law; to secure the ends of justice it is appropriate that the criminal case is put to an end.ratio¶17
As the parties did not wish to pursue the case any further and the matter was mutually settled in view of the compromise dated 15.7.2025, no useful purpose would be served in proceeding with the matter further.

Detailed headnote1 paragraphs

Allahabad High Court (Vikram D. Chauhan, J.) allowed an application under Section 528 BNSS (No. 19984 of 2025, decided September 9, 2025) seeking quashing of charge sheet no. 01 dated 21.11.2023 and the cognizance order dated 06.12.2024 in Case Crime No. 154 of 2023 (State Vs. Sanjeev & others) under Sections 498A, 323, 504, 506 I.P.C. and Section 3/4 D.P. Act, Police Station Falavda, District Meerut, pending before the Additional Civil Judge (J.D.) IIIrd Meerut. The case arose out of a matrimonial dispute; the parties had entered into a compromise dated 15.7.2025, verified by the court concerned on 5.8.2025, and the learned AGA raised no objection, conceding there was virtually no chance of conviction. Holding that continuance of the proceedings would be an exercise in futility and would tantamount to abuse of process of law, and in view of the principles laid down in Parbatbhai Aahir v. State of Gujarat, (2017) 9 SCC 641, Gian Singh v. State of Punjab, (2012) 10 SCC 303 and State of M.P. v. Laxmi Narayan, (2019) 5 SCC 688, the Court quashed the criminal proceedings and allowed the application.

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HIGH COURT OF JUDICATURE AT ALLAHABAD

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APPLICATION U/S 528 BNSS No. - 19984 of 2025

Sanjeev And 2 Others

.....Applicant(s)

Versus

State of U.P. and Another	.....Opposite Party(s)
Counsel for Applicant(s)	: Satendra Singh
Counsel for Opposite Party(s)	: G.A.

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Court No. - 76

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HON'BLE VIKRAM D. CHAUHAN, J.

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Heard learned counsel for the applicants and learned A.G.A. for the State.

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The present application has been filed by the applicants for quashing the entire proceeding of impugned charge sheet no. 01 dated 21.11.2023 as well as cognizance order dated 06.12.2024 in Case Crime No. 154 of 2023 (State Vs. Sanjeev & others), under Sections 498A, 323, 504, 506 I.P.C. & Section 3/4 D.P. Act, Police Station Falavda, District Meerut, pending in the court of Additional Civil Judge (J.D.) IIIrd Meerut.

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Learned counsel for the applicants submitted that the compromise has already been entered between the parties on 15.7.2025 and the same has been verified by the court concerned on 5.8.2025, therefore, the present case be finally decided.

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Learned AGA does not dispute the fact that parties have entered into settlement which is duly verified by the court concerned. It is further submitted that he would have no objection in case criminal proceedings are put to an end. He further submits that in view of settlement there is virtually no chance of any conviction being recorded in the criminal proceedings.

¶13

Having examined the matter in its totality, this Court is of the view that the criminal proceedings in the present case had essentially been an outcome of a matrimonial dispute and there are no such over bearing

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NA528 No. 19984 of 2025

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¶16

circumstances for which the applicants ought to be prosecuted even after the parties has entered into a settlement. Needless to observe that with the present stand of the parties in terms of their settlement, there is practically no chance of recording conviction, even if the case under the F.I.R. in question is put to trial. In other words, entire exercise of trial would only be an exercise in futility. On the contrary, looking to the nature of dispute and the fact that the disputants have compromised and want to proceed peacefully ahead, it would be in the interest of justice that criminal proceedings in question are quashed.

¶17

It would be unfair or contrary to the interest of justice to continue with the criminal proceeding or continuation of the criminal proceeding would tantamount to abuse of process of law despite settlement and compromise between the victim and the wrongdoer and to secure the ends of justice, it is appropriate that the criminal case is put to an end.

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In view of the fact that the parties do not want to pursue the case any further as stated by them and the fact that matter has been mutually settled between the parties in view of the compromise dated 15.7.2025, no useful purpose would be served in proceeding with the matter further.

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Thus, in view of the well settled principles of law as laid down by the Hon'ble Apex Court in Parbatbhai Aahir Vs. State of Gujarat (2017) 9 SCC 641, Gian Singh Vs. State of Punjab (2012) 10 SCC 303 and State of M.P. Vs. Laxmi Narayan, (2019) 5 SCC 688 , the proceedings of the aforesaid case is hereby quashed.

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The present application is, accordingly, allowed.

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(Vikram D. Chauhan,J.)

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September 9, 2025 VMA

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Digitally signed by :- VISHWA MOHAN ARORA High Court of Judicature at Allahabad

Sanjeev and 2 Others v. State of U.P. and Another

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Sanjeev and 2 Others v. State of U.P. and Another

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