Allowed¶11

Jai Kumar & Ors. v. State NCT of Delhi & Anr.

Quashing of FIR – matrimonial dispute

Delhi HC8 Dec 2025CRL.M.C./8751/2025

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Case brief

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What is this about?

Delhi High Court (Ravinder Dudeja, J.), 08.12.2025, CRL.M.C. 8751/2025: quashing of FIR No. 673/2021 PS Uttam Nagar under Sections 498A/406/34 IPC on amicable matrimonial settlement dated 31.08.2025; Section 528 BNSS petition; inherent powers under section 482; non-compoundable offence quashed; resumed cohabitation; reliance on Rangappa Javoor, Jitendra Raghuvanshi, Gian Singh, B.S. Joshi; FIR and consequential proceedings quashed; petition allowed and disposed.

What did the court decide?

Petition allowed and disposed of; FIR No. 673/2021 dated 26.08.2021 registered at P.S Uttam Nagar, Delhi under Sections 498A/406/34 IPC and all consequential proceedings emanating therefrom quashed; pending application(s), if any, disposed of. ¶11

Jai Kumar & Ors. Vs State 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. 673/2021 dated 26.08.2021 registered at P.S Uttam Nagar, Delhi under Sections 498A/406 IPC, and all proceedings emanating therefrom, should be quashed on the basis of the amicable settlement between the parties.

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Court's answer

It is settled that the inherent powers under section 482 of the Code are to be exercised to secure the ends of justice or to prevent abuse of the process of any court, and the High Court can quash non-compoundable offences after considering the nature of the offence and the amicable settlement between the concerned parties; cases arising out of matrimonial differences should be put to a quietus if the parties have reached an amicable settlement.

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Ratio / Principle

Since the parties have amicably resolved their differences out of their own free will and without any coercion, it would be in the interest of justice to quash the FIR and the proceedings pursuant thereto.

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Key takeaways

The petition is allowed and FIR No. 673/2021 dated 26.08.2021 registered at P.S Uttam Nagar, Delhi under Sections 498A/406/34 IPC, and all other consequential proceedings emanating therefrom, are quashed.ratio¶11

Detailed headnote1 paragraphs

Quashing of FIR — matrimonial dispute — petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita by husband and his family members seeking quashing of FIR No. 673/2021 dated 26.08.2021 registered at P.S Uttam Nagar, Delhi under Sections 498A/406 IPC (chargesheet subsequently filed under Sections 498A/406/34 IPC) on the basis of Settlement Agreement dated 31.08.2025. Parties physically present and identified; petitioner no.1 and respondent no.2 (complainant wife) had resumed cohabitation for about three years and were living together in peace and harmony per the settlement schedule. Respondent No. 2 confirmed settlement without any force, fear or coercion and raised no objection to quashing; learned Additional PP for the State likewise had no objection. Relying on Rangappa Javoor (Diary No. 33313/2019, 2023 LiveLaw (SC) 74), Jitendra Raghuvanshi (2013) 4 SCC 58, Gian Singh (2012) 10 SCC 303 and B.S. Joshi (2003) 4 SCC, the Court held that inherent powers are exercisable to secure the ends of justice, that non-compoundable offences can be quashed considering the nature of the offence and the amicable settlement, and that matrimonial-difference cases should be put to a quietus upon amicable settlement. FIR No. 673/2021 and all consequential proceedings quashed; petition allowed and disposed of; pending application(s) disposed of.

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$~74

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*** I� THE HIGH COURT OF DELHI AT �EW DELHI**

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% Date of decision: 08.12.2025

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CRL.M.C. 8751/2025 JAI KUMAR & ORS. .....Petitioners Through: Mr. Lalit Chauhan, Mr. Rajesh Chauhan, Ms. Nikita Chauhan, Mr. Jai Kumar, Mr. Vinod Kumar, Mr. Vijay Kumar, Ms. Shri Raj, Advs. along with petitioners in person.

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versus

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STATE NCT OF DELHI & ANR. .....Respondents Through: Ms. Manjeet Arya, APP with Insp. Kuldeep Singh, PS Uttam Nagar and SI Sumita. Ms. Pooja Kumari, Adv. for R- 2 along with R-2 in person.

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CORAM:HO�'BLE MR. JUSTICE RAVI�DER DUDEJA

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JUDGME�T(ORAL)

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RAVI�DER DUDEJA, J.

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This is a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, seeking quashing of FIR No. 673/2021, dated 26.08.2021, registered at P.S Uttam Nagar, Delhi under Sections 498A/406 IPC and all proceedings emanating therefrom on the basis of settlement between the parties.

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CRL.M.C. 8751/2025 Page 1 of 4

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Signature Not Verified Digitally Signed By:VAISHALI PRUTHI Signing Da te:0 9.12.2025 10:42:00

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The factual matrix giving rise to the instant case is that the marriage between Petitioner No. 1 and Respondent no. 2/complainant was solemnized on 20.02.2011 as per Hindu Rites and ceremonies at Delhi. Two children were born out of the said wedlock. However, on account of temperamental differences Petitioner No. 1 and Respondent No. 2 lived separately for about one year.

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As per averments made in the FIR, Respondent No. 2 was subjected to physical and mental harassment on account of dowry demands by the petitioners. FIR No. 673/2021 was lodged at the instance of respondent no. 2 at PS Uttam Nagar under sections 498A/406 IPC against the petitioners. Subsequently Chargesheet was filed under Sections 498A/406/34 IPC.

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During the course of proceedings, the parties amicably resolved their disputes and the terms of settlement were written in the form of Settlement Agreement dated 31.08.2025.It is submitted that the petitioner no.1 and respondent No. 2 have resumed cohabitation since last about three years and are presently living together in an atmosphere of peace and harmony as per the schedule in the settlement. Copy of the settlement agreement dated 31.08.2025has been annexed as Annexure P-3.

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Parties are physically present before the Court. They have been identified by their respective counsels as well as by the Investigating Officer Insp. Kuldeep Singh and SI Sumita, from PS Uttam Nagar.

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CRL.M.C. 8751/2025 Page 2 of 4

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Signature Not Verified Digitally Signed By:VAISHALI PRUTHI Signing Da te:0 9.12.2025 10:42:00

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Respondent No. 2 confirms that the matter has been amicably settled with the petitioners without any force, fear, coercion and she has no objection if the FIR No. 673/2021 is quashed against the Petitioners.

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In view of the settlement between the parties, learned Additional PP appearing for the State, also has no objection if the present FIR No. 673/2021 is quashed.

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Hon’ble Supreme Court has recognized the need of amicable settlement of disputes in Rangappa Javoor vs The State Of Karnataka And Another , Diary No. 33313/2019, 2023 LiveLaw (SC) 74, Jitendra Raghuvanshi& Ors. vs Babita Raghuvanshi &Anr., (2013) 4 SCC 58& in Gian Singh vs State of Punjab (2012) 10 SCC 303 .

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Further, it is settled that the inherent powers under section 482 of the Code are required to be exercised to secure the ends of justice or to prevent abuse of the process of any court. Further, the High Court can quash non-compoundable offences after considering the nature of the offence and the amicable settlement between the concerned parties. Supreme Court and this Court have repeatedly held that the cases arising out of matrimonial differences should be put to a quietus if the parties have reached an amicable settlement. Reliance may be placed upon B.S. Joshi v. State of Haryana, (2003) 4 SCC .

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CRL.M.C. 8751/2025 Page 3 of 4

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Signature Not Verified Digitally Signed By:VAISHALI PRUTHI Signing Da te:0 9.12.2025 10:42:00

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In view of the above facts that the parties have amicably resolved their differences out of their own free will and without any coercion, it would be in the interest of justice, to quash the abovementioned FIR and the proceedings pursuant thereto.

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In the interest of justice, the petition is allowed, and the FIR No. 673/2021, dated 26.08.2021, registered at P.S Uttam Nagar, Delhi under Sections 498A/406/34 IPC and all the other consequential proceeding emanating therefrom is hereby quashed.

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Petition is allowed and disposed of accordingly.

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Pending application(s), if any, also stand disposed of.

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RAVI�DER DUDEJA, J December 8, 2025 MA

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CRL.M.C. 8751/2025 Page 4 of 4

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Signature Not Verified

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Digitally Signed By:VAISHALI PRUTHI Signing Da te:0 9.12.2025 10:42:00

Jai Kumar & Ors. v. State NCT of Delhi & Anr.

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Jai Kumar & Ors. v. State NCT of Delhi & Anr.

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