Sanovar Khan and 4 Others Vs State of Up and Another — Dowry and Cruelty | Allahabad HC (2026)

Sanovar Khan and 4 Others Vs State of Up and Another — Dowry and Cruelty | Allahabad HC (2026)

What the court decided

AI extract

Outcome

Application disposed of with directions: parties to appear in person before the Trial Court with the compromise deed and certified copy of the order within three weeks; Trial Court to verify the compromise, record the parties' statements on fulfilment of its terms, and pass an appropriate order in accordance with law preferably within three months; no coercive action against the applicants till verification; liberty reserved to the applicants to approach the High Court again for quashing after verification.

Issue for consideration

Whether the entire proceedings pursuant to the charge sheet dated 04.03.2020 and cognizance order dated 30.11.2020 in Case Crime No. 1338 of 2019 (Case No. 3185 of 2020) ought to be quashed in view of the compromise dated 23.12.2025 between the parties. +1 more

Court's answer

The Court expressly refrained from expressing any opinion on the merits of the case.

Ratio / Principle

Both parties were directed to appear in person before the Trial Court with the compromise deed and a certified copy of the order within three weeks; the Trial Court was expected to fix a date, ensure the presence of the parties, and pass an appropriate order on the compromise in accordance with law, preferably within three months of production of the certified copy, subject to there being no other legal impediment.

Key takeaways

While verifying the compromise, the Trial Court shall also record the statements of the parties as to whether all terms and conditions of the original compromise deed have been fulfilled.ratio¶19
After verification, the parties may obtain a certified copy of the report and the compromise, and it will be open to the applicants to approach the High Court again for quashing of the proceedings.ratio¶20
As an interim measure, no coercive action shall be taken against the applicants in the aforesaid case until the compromise is verified by the Court concerned.

Detailed headnote1 paragraphs

Allahabad High Court (Nand Prabha Shukla, J.) disposed of an application under Section 528 BNSS seeking quashing of the charge sheet dated 04.03.2020 and cognizance order dated 30.11.2020 passed by the Chief Judicial Magistrate, Jalaun at Orai in Case Crime No. 1338 of 2019 (trial Case No. 3185 of 2020, State Vs. Sanovar Khan and others) under Sections 498-A, 354, 323 IPC, Sections 3/4 Dowry Prohibition Act and Sections 3/4 Muslim Women (Protection of Rights on Marriage) Act, P.S. Kotwali Orai, District Jalaun, in view of a compromise dated 23.12.2025 between the parties. Without expressing any opinion on the merits, the Court directed both parties to appear in person before the Trial Court with the compromise deed and a certified copy of the order within three weeks; the Trial Court was to verify the compromise, record the parties' statements on fulfilment of its terms, and pass an appropriate order in accordance with law preferably within three months. Till such verification, no coercive action was to be taken against the applicants, with liberty to approach the High Court again for quashing thereafter.

HIGH COURT OF JUDICATURE AT ALLAHABAD

APPLICATION U/S 528 BNSS No. - 9642 of 2026

Sanovar Khan And 4 Others

.....Applicant(s)

Versus

State of U.P. and Another

.....Opposite Party(s)

Counsel for Applicant(s)	: Rakesh Kumar Bharti
Counsel for Opposite Party(s)	: G.A., Rahul Kumar

Court No. - 78

HON'BLE NAND PRABHA SHUKLA, J.

Heard Mr. Rakesh Kumar Bharti, learned counsel for the applicants, Mr. Rahul Kumar, learned counsel for the opposite party No. 2, learned A.G.A. for the State and perused the record.

The present application under Section 528 B.N.S.S. has been filed to allow the instant application and quash the entire proceeding of the impugned charge sheet dated 04.03.2020 as well as cognizance order dated 30.11.2020 passed by the Chief Judicial Magistrate, Jalaun at Orai in Case Crime No. 1338 of 2019, under Sections 498-A, 354, 323 I.P.C. & Section 3/4 D.P. Act and Section 3/4 (Muslim women protection of Marriage Right) Act, Police Station-Kotwali Orai, District-Jalaun against the applicant No.4 and Sections 498-A, 323 I.P.C. & 3/4 D.P. Act & Section 3/4 Muslim Women (the Protection of Right on Marriage), against the applicant Nos. 1, 2 & 3, pending before the Chief Judicial Magistrate, Jaluan at Orai in Case No. 3185 of 2020 (State Vs. Sanovar Khan and others) and to stay the further proceeding of the aforesaid case.

Learned counsel for the applicants submits that the parties have amicably settled their disputes vide compromise dated 23.12.2025, which has been placed as Annexure No. '5' to the present application. Therefore, no useful purpose would be served in continuing the proceedings before the Court concerned and the same is not only sheer wastage of time of the Court but also abuse of process of law.

Learned counsel for the opposite party No. 2 does not dispute the submissions advanced by the learned counsel for the applicants or

NA528 No. 9642 of 2026

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correctness of the documents relied upon by him.

Learned A.G.A., however, submits that it is the Trial Court, which has to verify the fact as to whether the parties have entered into compromise, hence the applicants may approach the concerned Court and move an application with respect to compromise between the parties, which will be decided in accordance with law.

In view of above, without expressing any opinion on the merits of the case, both the parties are directed to appear in person before the Trial Court along with compromise deed as well certified copy of this order within three weeks from today. It is expected that Court concerned may fix a date for the verification of the compromise and after ensuring the presence of the parties, pass an appropriate order with respect to the same in accordance with law, as expeditiously as possible, after giving opportunity of hearing to both the parties, preferably within a period of three months from the date of production of a certified copy of this order, if there is no other legal impediment. While passing the order verifying the compromise, the Court concerned shall also record the statements of the parties as to whether all the terms and conditions mentioned in the original compromise deed, so filed, have been fulfilled or not.

The Court in that scenario will allow the parties to obtain certified copy of the report as well as compromise and it will be open to the applicants to approach this Court again for quashing of the proceedings.

Till verification of compromise between the parties by the Court concerned, no coercive action shall be taken against the applicants in the aforesaid case.

With the aforesaid directions, this application is disposed of .

March 25, 2026 Shivani

(Nand Prabha Shukla,J.)

Digitally signed by :- SHIVANI SRIVASTAVA High Court of Judicature at Allahabad