Allowed¶34

Meena Khatoon v. the State of NCT of Delhi & Anr.

Quashing of FIR – Section 528 BNSS (earlier Section 482 CrPC)

Delhi HC12 Dec 2025CRL.M.C./1134/2025

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What is this about?

Quashing of FIR; Section 528 BNSS; Section 482 CrPC; Section 307 IPC; attempt to murder; non-compoundable offence; matrimonial dispute; compromise deed; settlement dated 30.01.2025; voluntary settlement; PS Shahbad Dairy; FIR No.108/2020; Meena Khatoon; State of NCT of Delhi; Laxmi Narayan (2019) 5 SCC 688; Ramgopal (2021 INSC 568); consequential proceedings quashed; CRL.M.C. 1134/2025; Delhi High Court; Ajay Digpaul.

What did the court decide?

FIR No.108/2020 registered at Police Station – Shahbad Dairy for offences punishable under Sections 307 IPC, and all consequential proceedings emanating therefrom, stand quashed qua the present petitioner; the petition, along-with pending application(s), if any, stands disposed of. ¶34

Meena Khatoon Vs the State of NCT of Delhi & Anr. — Delhi HC (2025) — LawSathi Research

What the court decided

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Outcome

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Issue for consideration

Whether FIR No.108/2020, PS Shahbad Dairy (Sections 307 IPC), should be quashed on the basis of the Compromise Deed/settlement arrived at between the petitioner and respondent no.2. +1 more

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Court's answer

The instant criminal proceedings concern non-compoundable offences that are private in nature and do not have a serious impact on society, especially given the settlement/compromise between the victim and the accused.

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Ratio / Principle

In such cases, it is settled law that the High Court is required to consider the conduct and antecedents of the accused to ascertain that the settlement was entered into by his own free will and was not imposed upon him.

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Key takeaways

The complainant/respondent no.2, present in Court, categorically stated that he entered into the compromise and settled the entirety of disputes with the petitioner amicably and of his own free will, without any pressure or coercion, had no complaint of bad conduct by the petitioner after the compromise, and had no objection to the FIR being quashed.ratio¶32
Since the parties are married, the dispute arose out of matrimonial discord, they are moving forward in their matrimonial life, and in view of the settlement and the law laid down by the Hon'ble Supreme Court, the petition is allowed and FIR No.108/2020 with all consequential proceedings stands quashed qua the petitioner.ratio¶34

Detailed headnote1 paragraphs

Quashing of FIR – Section 528 BNSS (earlier Section 482 CrPC) – FIR No.108/2020, PS Shahbad Dairy, under Sections 307 IPC (attempt to murder), arising out of a matrimonial dispute between spouses – parties entered into a settlement dated 30.01.2025 evidenced by a Compromise Deed – offence non-compoundable but private in nature, without serious impact on society – complainant/respondent no.2 present in Court and confirmed the compromise was amicable, voluntary and without pressure or coercion, and raised no objection to quashing – State raised no opposition – relying on State of Madhya Pradesh v. Laxmi Narayan (2019) 5 SCC 688 and Ramgopal v. State of Madhya Pradesh (2021 INSC 568), the High Court allowed the petition and quashed the FIR and all consequential proceedings qua the petitioner (Ajay Digpaul, J).

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- CRL.M.C. 1134/2025 & CRL.M.A. 5103/2025

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MEENA KHATOON .....Petitioner

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Through: Mr. Om Prakash, Adv. Petitioner in person.

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versus

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THE STATE OF NCT OF DELHI & ANR. .....Respondents Through: Mr. Raghuinder Verma, APP for State with Mr. Aditya Vikram Singh, Adv. SI Ram Singh, PS Shahbad Dairy Respondent no.2 in person.

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CORAM:

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HON'BLE MR. JUSTICE AJAY DIGPAUL

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O R D E R % 12.12.2025

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1. The instant petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (hereinafter “BNSS”) [earlier Section 482 of the Code of Criminal Procedure, 1973 (hereinafter “CrPC”)] has been filed on behalf of the petitioner praying for the quashing of FIR No.108/2020, registered at Police Station – Shahbad Dairy, for offences punishable under Sections 307 of the Indian Penal Code, 1860 (hereinafter “IPC”).

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2. The allegations, as set out in the FIR state that on the intervening night of 22/23.032020, a matrimonial dispute arose between the complainant (husband) and the petitioner (wife) at their residence. It is alleged that following a quarrel over household issues and a mobile charger, the petitioner became aggressive, threatened to kill the complainant, and allegedly picked up a kitchen/vegetable knife and stabbed him in the chest

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 19/12/2025 at 13:10:54

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with the intention to cause his death. As a result of the alleged assault, the complainant sustained stab injuries and was taken by a neighbour to Dr. B.S.A. Hospital for treatment, where the police recorded his statement, leading to the registration of the present FIR against the petitioner for the offence of attempt to murder.

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3. Despite efforts of reconciliation, both the parties could not settle their differences, pursuant to which respondent no.2 got FIR No.108/2020 registered.

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4. However, at this stage, with the intervention of family members and relatives, both the parties have entered into a settlement dated 30.01.2025 and a Compromise Deed was executed between the parties. The terms and conditions of the said settlement are mentioned in the Compromise Deed which is annexed to the petition. In pursuance of the said settlement, the parties have jointly agreed to withdraw the pending litigation and that they shall now live in peace, and will make attempts to live a peaceful life.

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5. It is, thus, prayed that the instant FIR be quashed on the basis of Compromise Deed.

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6. Heard. Issue notice.

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7. Learned APP for the State, who appears on advance notice, accepts notice and submits that there is no opposition to the prayer made on behalf of the petitioner seeking quashing of the FIR in question in view of the settlement arrived at between the parties.

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8. Heard learned counsel for the parties and perused the record.

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9. The petitioner is present before this Court and has been identified by her counsel and the Investigating Officer, Police Station – Shahbad Dairy. Respondent no.2 is also present in the Court and has been identified by his

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 19/12/2025 at 13:10:54

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counsel and the concerned Investigating Officer.

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10. The instant criminal proceedings concern non-compoundable offences that are private in nature and do not have a serious impact on society, especially considering that there is a settlement/compromise between the victim and the accused.

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11. In such cases, it is settled law that High Court is also required to consider the conduct and antecedents of the accused in order to ascertain that the settlement has been entered into by his own free will and has not been imposed upon him by the petitioner or any person related to her.

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12. In the case of State of Madhya Pradesh v. Laxmi Narayan and Ors. (2019) 5 SCC 688 , the Hon’ble Supreme Court held that the powers conferred under Section 482 of the CrPC/Section 528 of the BNSS, can be exercised by the Courts to quash criminal proceedings featuring noncompoundable offences, when the matter arises out of matrimonial or family disputes. Moreover, it is pertinent to satisfy the Court that the said noncompoundable offences are private in nature and do not have a serious impact on society.

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13. Furthermore, it was observed by the Hon’ble Supreme Court in the case of Ramgopal and Ors. v. The State of Madhya Pradesh 2021 INSC 568 , that the extraordinary power enjoined upon the High Courts under Section 482 of the CrPC/Section 528 of the BNSS can be invoked even when such a case falls within the ambit of non-compoundable offences, given that the Court is satisfied that the nature of the offence does not impact the conscience of society, and that the compromise between the parties is voluntary and amicable.

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 19/12/2025 at 13:10:54

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14. In the present case, the complainant/respondent no.2 is present in Court and has categorically stated that he has entered into compromise and settled the entirety of disputes with the petitioner amicably and of his own free will, without any pressure or coercion. There is also no allegation from respondent no.2 that the conduct and antecedents of petitioner have been bad towards him after entering into this compromise. Further, he submits that he has no objection to the present FIR being quashed as he is now moving on with his life and focusing on his matrimonial life.

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15. Keeping in view that the parties are married, the dispute arose out of a matrimonial discord, the parties are moving forward in their matrimonial life, and in consideration of the settlement arrived at between the parties and the law laid down by the Hon’ble Supreme Court, the present petition is allowed.

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16. Accordingly, FIR No.108/2020, registered at Police Station – Shahbad Dairy, for offences punishable under Sections 307 of the IPC, and all consequential proceedings emanating therefrom stand quashed qua the present petitioner.

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17. The petition, along-with pending application(s), if any, stands disposed of.

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AJAY DIGPAUL, J

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DECEMBER 12, 2025/ AS/ryp

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 19/12/2025 at 13:10:54

Meena Khatoon v. the State of NCT of Delhi & Anr.

Case brief

What is this about?

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Meena Khatoon v. the State of NCT of Delhi & Anr.

Case brief

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