Vanshaj Kumar & Ors. v. NCT of Delhi & Anr.

Delhi HC17 Nov 2025W.P.(CRL)/3766/2025

Case brief

AI extract

What is this about?

FIR quashing on settlement; matrimonial dispute; Sections 498A/406/34/506/354/377 IPC; Section 528 BNSS; Article 226; non-compoundable offences private in nature; voluntary compromise verified in open court; Delhi Mediation Centre Tis Hazari; ₹37 lakh settlement; Section 13B Hindu Marriage Act divorce; State of M.P. v. Laxmi Narayan (2019) 5 SCC 688; Ramgopal v. State of M.P. (2021 INSC 568); PS Paschim Vihar East; W.P.(CRL) 3766/2025; Ajay Digpaul, J.

What did the court decide?

FIR bearing no.874/2023 registered at Police Station – Paschim Vihar East for offences punishable under Sections 498A/406/34/506/354/377 of the IPC, and all consequential proceedings emanating therefrom, quashed qua the present petitioners; petition along with pending application(s), if any, disposed of. ¶¶34

Vanshaj Kumar & Ors. Vs NCT of Delhi & Anr. — Dowry and Cruelty | Delhi HC (2025)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether FIR No. 874/2023 (Police Station – Paschim Vihar East; Sections 498A/406/34/506/354/377 IPC) and the proceedings arising therefrom should be quashed on the basis of the settlement/compromise reached between petitioner no.1 and respondent no.2.

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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 considering that there is a settlement/compromise between the victim and the accused.

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Ratio / Principle

In such cases the 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 the complainant of her own free will and has not been imposed upon her.

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Key takeaways

The Court found that complainant/respondent no.2, present in Court and identified by counsel and the Investigating Officer, categorically stated she entered the compromise and settled the entirety of disputes with the petitioners amicably and of her own free will, without any pressure or coercion; as per the Compromise Deed she received the entire settled amount, raised no allegation of bad conduct/antecedents after the compromise, and had no objection to the FIR being quashed.ratio¶¶33
In view of the settlement arrived at between the parties and the law laid down by the Hon'ble Supreme Court, the petition is allowed and FIR bearing no.874/2023, registered at Police Station – Paschim Vihar East for offences punishable under Sections 498A/406/34/506/354/377 of the IPC, and all consequential proceedings emanating therefrom stand quashed qua the present petitioners; the petition along with pending application(s), if any, stands disposed of.ratio¶¶34

Detailed headnote1 paragraphs

Criminal W.P.(CRL) 3766/2025 | High Court of Delhi (Single Bench: Ajay Digpaul, J) | Order dated 17.11.2025 | Petition under Article 226 of the Constitution read with Section 528 BNSS allowed: FIR No. 874/2023 (PS Paschim Vihar East; Sections 498A/406/34/506/354/377 IPC) arising from a matrimonial dispute (marriage solemnized 10.07.2016) between petitioner no.1 and respondent no.2, together with all consequential proceedings, quashed qua the petitioners. Grounds: parties entered a settlement on 12.02.2025 before the Delhi Mediation Centre, Tis Hazari Courts, whereby respondent no.2 settled all claims (dowry articles, stridhan, marriage expenses, jewellery, gifts, past/present/future maintenance and permanent alimony) for a total of ₹37,00,000/- and the parties agreed to move for divorce under Section 13B(1) and 13B(2) Hindu Marriage Act, 1955; relying on State of Madhya Pradesh vs. Laxmi Narayan and Ors. (2019) 5 SCC 688 and Ramgopal and Ors. vs. The State of Madhya Pradesh 2021 INSC 568, the Court treated the non-compoundable offences as private in nature without serious impact on society, verified respondent no.2's presence, identification, voluntary and uncoerced consent, receipt of the entire settled amount and lack of objection, and allowed the quashing; children from the wedlock, if any, remain free to assert their rights in accordance with law; pending applications disposed of.

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$~79

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(CRL) 3766/2025

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VANSHAJ KUMAR & ORS. .....Petitioners

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Through: Mr. Akshat Gupta and Mr. Sriram, Advs. Petitioners in Person.

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versus

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NCT OF DELHI & ANR. .....Respondents Through: Mr. Sanjay Lao, Standing Counsel (Criminal) for State. 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 % 17.11.2025

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1. The instant petition under Article 226 of the Constitution of India read with Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (hereinafter “BNSS”) has been filed on behalf of the petitioners praying for the quashing of FIR bearing no.874/2023, registered at Police Station – Paschim Vihar East, for offences punishable under Sections 498A/406/34/506/354/377 of the Indian Penal Code, 1860 (hereinafter “IPC”).

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2. The brief facts concerning the present dispute are that the marriage between petitioner no.1 and respondent no.2 was solemnized on 10.07.2016, according to Hindu rites and ceremonies. However, due to some temperamental differences between them, shortly after their marriage, they

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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 24/11/2025 at 12:27:51

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started living separately.

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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.874/2023 registered.

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4. However, at this stage, with the intervention of family members and relatives, both the parties have entered a settlement on 12.02.2025 before the Delhi Mediation Centre, Tis Hazari Courts. The terms and conditions of the said settlement are mentioned in the Settlement Deed which is annexed as “Annexure P/2” to the petition. In pursuance of the said settlement, the parties have jointly agreed that they shall move for divorce under Section 13B (1) and under Section 13B (2) of the Hindu Marriage Act, 1955.

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5. Learned counsel appearing on behalf of the petitioners submitted that respondent no.2 has settled all her claims in respect of her dowry articles, stridhan , marriage expenses, jewelleries, gift items and claims of past, present and future maintenance and permanent alimony with the petitioners and all disputes of any nature whatsoever, for a total sum of ₹37,00,000/which is inclusive of the Settlement dated 12.02.2025, executed before the Delhi Mediation Centre, Tis Hazari Courts as well as Memorandum of Understanding dated 12.02.2025.

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6. It is, thus, prayed that the instant FIR be quashed on the basis of compromise.

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7. Heard. Issue notice.

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8. Learned Standing Counsel 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 petitioners seeking quashing of the FIR in question in view of the settlement arrived at between the parties.

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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 24/11/2025 at 12:27:51

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

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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 her own free will and has not been imposed upon her by the petitioners or any person related to them.

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12. In the case of State of Madhya Pradesh vs. 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. vs. 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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14. The petitioners are present before this Court and have been identified

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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 24/11/2025 at 12:27:51

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by their counsel and the Investigating Officer, Police Station – Paschim Vihar East. Respondent no.2 is also present in the Court and has been identified by her counsel and the concerned Investigating Officer.

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15. In the present case, the complainant/respondent no.2 is present in Court and has categorically stated that she has entered into compromise and settled the entirety of disputes with the petitioners amicably and of her own free will, without any pressure or coercion. There is also no allegation from respondent no.2 that the conduct and antecedents of petitioners have been bad towards her after entering into this compromise. As per the Compromise Deed, respondent no. 2 has received the entire settled amount. Further, she submits that she has no objection to the present FIR being quashed as she is now moving towards a peaceful future. The respondent no.2 is looking ahead and taking steps to rebuild and move on with her life.

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16. Therefore, in view of the settlement arrived at between the parties and the law laid down by the Hon’ble Supreme Court, the present petition is allowed. Accordingly, FIR bearing no.874/2023, registered at Police Station – Paschim Vihar East, for offences punishable under Sections 498A/406/34/506/354/377 of the IPC, and all consequential proceedings emanating therefrom stand quashed qua the present petitioners. 17. Children from the wedlock, if any, are free to assert their rights in accordance with law. 18. The petition, along-with pending application(s), if any, stands disposed of.

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AJAY DIGPAUL, J

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NOVEMBER 17, 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 24/11/2025 at 12:27:51

Vanshaj Kumar & Ors. v. NCT of Delhi & Anr.

Case brief

What is this about?

What did the court decide?

Vanshaj Kumar & Ors. v. NCT of Delhi & 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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Procedural history

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