Smt. Ramo Devi v. State through SHO Ps Budh Vihar & Anr.

Delhi HC7 Nov 2025CRL.M.C./3350/2025

Case brief

AI extract

What is this about?

Search terms: quashing of FIR on basis of compromise/settlement; Section 528 BNSS; Section 482 Cr.P.C.; inherent powers of the High Court; non-compoundable Section 498A IPC; compoundable Section 406 IPC; matrimonial dispute; cruelty complaint; Settlement Deed dated 21 September 2024; INR 45,000/- full and final settlement; Narinder Singh v. State of Punjab (2014) 6 SCC 466; Parbatbhai Aahir v. State of Gujarat (2017) 9 SCC 641; ends of justice; prevent abuse of process of court; predominantly civil character disputes; FIR No. 45/2019; P.S. Budh Vihar; SHO Budh Vihar; Delhi High Court; Justice Sanjeev Narula; order dated 07.11.2025.

What did the court decide?

Quashing of FIR No. 45/2019 and all consequential proceedings arising therefrom; parties to abide by the terms of the settlement; pending application disposed of. ¶¶68

Smt. Ramo Devi Vs State through SHO Ps Budh Vihar & Anr. — Dowry and Cruelty | Delhi HC (2025)

What the court decided

AI extract

Outcome

Quashing of FIR No. 45/2019 and all consequential proceedings arising therefrom; parties to abide by the terms of the settlement; pending application disposed of.

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Issue for consideration

Whether FIR No. 45/2019 and all proceedings emanating therefrom should be quashed in view of the amicable settlement voluntarily reached between the parties. +1 more

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Court's answer

The impugned FIR No. 45/2019 and all consequential proceedings arising therefrom are quashed.

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Ratio / Principle

Considering the nature of the dispute, the amicable settlement and the fact that the parties are happily residing together, the present case is fit for exercise of jurisdiction under Section 528 of BNSS, as no purpose would be served by keeping the dispute alive and continuance of the proceedings would amount to abuse of the process of the Court.

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Detailed headnote1 paragraphs

CRL.M.C. 3350/2025 (Delhi High Court, Hon'ble Mr. Justice Sanjeev Narula, order dated 07.11.2025): Petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (formerly Section 482 Cr.P.C.) by Smt. Ramo Devi, mother-in-law of Respondent No. 2, seeking quashing of FIR No. 45/2019 registered under Sections 498A/406/34 IPC at P.S. Budh Vihar following a complaint of cruelty amid matrimonial discord (marriage of 05.07.2018; couple childless and separated). The parties had voluntarily executed a Settlement Deed dated 21.09.2024 for payment of INR 45,000/- as full-and-final settlement, with Respondent No. 2 agreeing to withdraw all pending proceedings; she appeared in person, was identified by the Investigating Officer, raised no objection, affirmed voluntariness (supporting affidavit on record) and acknowledged receipt of the amount. Noting Section 498A IPC is non-compoundable while Section 406 IPC is compoundable in certain cases, the Court relied on the guidelines in Narinder Singh v. State of Punjab, (2014) 6 SCC 466 and Parbatbhai Aahir v. State of Gujarat, (2017) 9 SCC 641, and held that this matrimonial-dispute case was fit for exercise of jurisdiction under Section 528 BNSS since the parties had amicably settled and were happily residing together, no purpose would be served by keeping the dispute alive, and continuance would amount to abuse of the process of Court. FIR No. 45/2019 and all consequential proceedings quashed; parties directed to abide by settlement terms; pending application disposed of; petition allowed.

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$~36

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- CRL.M.C. 3350/2025 & CRL.M.A. 14753/2025

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SMT. RAMO DEVI .....Petitioner

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Through: Mr. Ranu Singh and Mr. Raghav Kapoor, Advocates with Petitioner in person

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versus

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STATE THROUGH SHO PS BUDH VIHAR & ANR.

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.....Respondents Through: Mr. Hemant Mehla, APP for the State with SI Manish Dahiya, SI Ravinder, PS Budh Vihar. Respondent No. 2 in person.

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CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA

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O R D E R % 07.11.2025

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The present petition filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023¹ (formerly Section 482 of the Code of Criminal Procedure, 1973² ) seeks quashing of FIR No. 45/2019³ registered under Sections 498A/406/34 of the Indian Penal Code, 1860⁴ at P.S. Budh Vihar, and all other proceedings emanating therefrom.

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The Petitioner is the mother-in-law of Respondent No. 2. The marriage between Respondent No. 2 and the Petitioner’s son was

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1 “BNSS”

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2 “Cr.P.C.”

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3 “the impugned FIR”

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4 “IPC”

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CRL.M.C. 3350/2025 Page 1 of 6

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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 14/11/2025 at 11:42:01

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solemnized on 05^th July, 2018 as per Hindu rites and ceremonies. The couple has no children from the marriage. Owing to matrimonial discord, the relationship between them deteriorated, and they have been living separately since. Efforts at reconciliation were undertaken but proved unsuccessful.

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Respondent No. 2 lodged a complaint alleging that the Petitioner and her family members subjected her to cruelty, which eventually led to the registration of the impugned FIR.

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The present petition is filed on the ground that the matter is amicably settled between the parties on their own free will, without any coercion, pressure or undue influence. The parties have executed a Settlement Deed dated 21^st September, 2024 in terms whereof the Petitioner has agreed to pay a total sum of INR 45,000/- to Respondent No. 2 as full and final settlement amount. Respondent No. 2 has agreed to withdraw all proceedings pending before various courts.

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Respondent No. 2, present in person, has been duly identified by the Investigating Officer, raises no objection to the quashing of the FIR. She confirms that the settlement is voluntary and free from any pressure, and her supporting affidavit to that effect is on record. She also acknowledges having received the full settlement amount in terms of the Settlement Deed. In these circumstances, counsel for both sides jointly request that the FIR be quashed.

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The Court has considered the afore-noted facts. Notably, offence under Section 498A of IPC is non-compoundable while offence under Section 406 of IPC is compoundable in certain cases.

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It is well-established that the High Courts, in exercise of their powers under Section 528 of BNSS (formerly Section 482 of Cr.P.C.), can

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CRL.M.C. 3350/2025 Page 2 of 6

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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 14/11/2025 at 11:42:01

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compound offences which are non-compoundable on the ground that there is a compromise between the accused and the complainant. In Narinder Singh & Ors. v. State of Punjab & Anr. ,⁵ the Supreme Court laid down guidelines for High Courts while accepting settlement deeds between parties and quashing the proceedings. The relevant observations in the said decision read as under:

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“29. In view of the aforesaid discussion, we sum up and lay down the following principles by which the High Court would be guided in giving adequate treatment to the settlement between the parties and exercising its power under Section 482 of the Code while accepting the settlement and quashing the proceedings or refusing to accept the settlement with direction to continue with the criminal proceedings:

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29.1. Power conferred under Section 482 of the Code is to be distinguished from the power which lies in the Court to compound the offences under Section 320 of the Code. No doubt, under Section 482 of the Code, the High Court has inherent power to quash the criminal proceedings even in those cases which are not compoundable, where the parties have settled the matter between themselves. However, this power is to be exercised sparingly and with caution.

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29.2. When the parties have reached the settlement and on that basis petition for quashing the criminal proceedings is filed, the guiding factor in such cases would be to secure: (i) ends of justice, or (ii) to prevent abuse of the process of any court.

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While exercising the power the High Court is to form an opinion on either of the aforesaid two objectives.

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29.3. Such a power is not to be exercised in those prosecutions which involve heinous and serious offences of mental depravity or offences like murder, rape, dacoity, etc. Such offences are not private in nature and have a serious impact on society. Similarly, for the offences alleged to have been committed under special statute like the Prevention of Corruption Act or the offences committed by public servants while working in that capacity are not to be quashed merely on the basis of compromise between the victim and the offender.

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5 (2014) 6 SCC 466

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CRL.M.C. 3350/2025 Page 3 of 6

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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 14/11/2025 at 11:42:01

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29.4. On the other hand, those criminal cases having overwhelmingly and predominantly civil character, particularly those arising out of commercial transactions or arising out of matrimonial relationship or family disputes should be quashed when the parties have resolved their entire disputes among themselves.

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29.5. While exercising its powers, the High Court is to examine as to whether the possibility of conviction is remote and bleak and continuation of criminal cases would put the accused to great oppression and prejudice and extreme injustice would be caused to him by not quashing the criminal cases.”

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[Emphasis Supplied]

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8 . Similarly, in the case of Parbatbhai Aahir & Ors. v. State of Gujarat

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& Anr. ,⁶ the Supreme Court had observed as under:

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“16. The broad principles which emerge from the precedents on the subject, may be summarised in the following propositions:

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16.1. Section 482 preserves the inherent powers of the High Court to prevent an abuse of the process of any court or to secure the ends of justice. The provision does not confer new powers. It only recognises and preserves powers which inhere in the High Court.

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16.2. The invocation of the jurisdiction of the High Court to quash a first information report or a criminal proceeding on the ground that a settlement has been arrived at between the offender and the victim is not the same as the invocation of jurisdiction for the purpose of compounding an offence. While compounding an offence, the power of the court is governed by the provisions of Section 320 of the Code of Criminal Procedure, 1973. The power to quash under Section 482 is attracted even if the offence is noncompoundable.

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16.3. In forming an opinion whether a criminal proceeding or complaint should be quashed in exercise of its jurisdiction under Section 482, the High Court must evaluate whether the ends of justice would justify the exercise of the inherent power.

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16.4. While the inherent power of the High Court has a wide ambit and plenitude it has to be exercised (i) to secure the ends of justice, or (ii) to

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6 (2017) 9 SCC 641

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CRL.M.C. 3350/2025 Page 4 of 6

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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 14/11/2025 at 11:42:01

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prevent an abuse of the process of any court.

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16.5. The decision as to whether a complaint or first information report should be quashed on the ground that the offender and victim have settled the dispute, revolves ultimately on the facts and circumstances of each case and no exhaustive elaboration of principles can be formulated.

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16.6. In the exercise of the power under Section 482 and while dealing with a plea that the dispute has been settled, the High Court must have due regard to the nature and gravity of the offence. Heinous and serious offences involving mental depravity or offences such as murder, rape and dacoity cannot appropriately be quashed though the victim or the family of the victim have settled the dispute. Such offences are, truly speaking, not private in nature but have a serious impact upon society. The decision to continue with the trial in such cases is founded on the overriding element of public interest in punishing persons for serious offences.

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16.7. As distinguished from serious offences, there may be criminal cases which have an overwhelming or predominant element of a civil dispute. They stand on a distinct footing insofar as the exercise of the inherent power to quash is concerned.

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16.8. Criminal cases involving offences which arise from commercial, financial, mercantile, partnership or similar transactions with an essentially civil flavour may in appropriate situations fall for quashing where parties have settled the dispute.

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16.9. In such a case, the High Court may quash the criminal proceeding if in view of the compromise between the disputants, the possibility of a conviction is remote and the continuation of a criminal proceeding would cause oppression and prejudice; and

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16.10. There is yet an exception to the principle set out in propositions 16.8. and 16.9. above. Economic offences involving the financial and economic well-being of the State have implications which lie beyond the domain of a mere dispute between private disputants. The High Court would be justified in declining to quash where the offender is involved in an activity akin to a financial or economic fraud or misdemeanour. The consequences of the act complained of upon the financial or economic system will weigh in the balance.”

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[Emphasis Supplied]

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Considering the nature of dispute and the fact that the parties have

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CRL.M.C. 3350/2025 Page 5 of 6

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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 14/11/2025 at 11:42:01

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amicably entered into a settlement and are happily residing together, this Court is of the opinion that the present case is fit to exercise jurisdiction under Section 528 of BNSS as no purpose would be served by keeping the dispute alive and continuance of the proceedings would amount to abuse of the process of Court.

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In view of the above, the impugned FIR No. 45/2019 and all consequential proceedings arising therefrom are hereby quashed.

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Parties shall abide by the terms of the settlement.

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The present petition is allowed in the aforesaid terms. Pending application also stands disposed of.

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SANJEEV NARULA, J

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NOVEMBER 7, 2025/ab

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CRL.M.C. 3350/2025 Page 6 of 6

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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 14/11/2025 at 11:42:01

Smt. Ramo Devi v. State through SHO Ps Budh Vihar & Anr.

Case brief

What is this about?

What did the court decide?

Smt. Ramo Devi v. State through SHO Ps Budh Vihar & Anr.

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Cases cited

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