Disposed¶29

Abhishek Kumar & Ors. v. the State Govt of NCT of Delhi & Anr.

Quashing of FIR – matrimonial dispute

Delhi HC12 Jan 2026CRL.M.C./222/2026

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Case brief

AI extract

What is this about?

Quashing of FIR on compromise/settlement in matrimonial (criminal) dispute; Section 406 IPC; FIR No. 1357/2015 P.S. Amar Colony; inherent powers under Section 528 BNSS; voluntary settlement, Rs. 30 lacs received towards maintenance/istridhan/alimony; divorce decree 28.06.2021; related 498A IPC and Dowry Prohibition Act case (FIR 85/2014, Sitamarhi) quashed by Patna High Court in Crl. Revision 101/2021; charge-sheet filed, charges unascertained; CRL.M.C. 222/2026; Manoj Jain, J.; decided 12.01.2026.

What did the court decide?

FIR No. 1357/2015 dated 21.12.2020 (P.S. Amar Colony, Section 406 IPC) and all consequential proceedings emanating therefrom quashed under Section 528 BNSS to secure the ends of justice; petition disposed of in those terms ¶29

Abhishek Kumar & Ors. Vs the State Govt of NCT of Delhi & Anr. — Dowry and Cruelty | Delhi HC (2026)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether FIR No. 1357/2015 dated 21.12.2020 registered at P.S. Amar Colony under Section 406 IPC, along with consequential proceedings arising therefrom, should be quashed on the basis of the compromise/settlement arrived at between the parties.

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Court's answer

In view of the settlement between the parties, continuing with the criminal proceedings would serve no useful purpose, as the dispute involves no public interest and is private in nature; moreover, the complainant herself does not wish to press charges against the petitioners.

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Ratio / Principle

Exercising its inherent powers under Section 528 of the BNSS, the Court found it appropriate to quash the FIR in question.

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Key takeaways

To secure the ends of justice, FIR No. 1357/2015 dated 21.12.2020, registered at P.S. Amar Colony under Section 406 IPC, along with all consequential proceedings emanating therefrom, stands quashed; the petition is disposed of accordingly.ratio¶29

Detailed headnote1 paragraphs

Quashing of FIR — matrimonial dispute — settlement/compromise between parties. Petitioners sought quashing of FIR No. 1357/2015 dated 21.12.2020, P.S. Amar Colony, under Section 406 IPC, with consequential proceedings, on the basis of compromise. Respondent No.2 (complainant, married to petitioner no.1 on 28.06.2012), a practising advocate, appeared in person and affirmed that she entered the settlement voluntarily, free of undue influence or coercion, having received the entire settlement amount of Rs. 30 lacs in lieu of maintenance, istridhan and alimony; the parties had already obtained a decree of divorce dated 28.06.2021 and had no offspring. A related FIR No. 85/2014 (P.S. Dumra, Distt. Sitamarhi) under Section 498A IPC and Sections 3, 4 of the Dowry Prohibition Act, 1961, which had resulted in conviction, stood earlier quashed by the High Court of Judicature at Patna in Criminal Revision No. 101/2021 vide order dated 23.08.2022 in view of the same compromise. Though a charge-sheet had been filed, charges were yet to be ascertained. Holding that continuing the proceedings would serve no useful purpose as the dispute was private and involved no public interest, and noting that the complainant did not wish to press charges, the Court (Manoj Jain, J.), exercising inherent powers under Section 528 of the BNSS, quashed the FIR and all consequential proceedings to secure the ends of justice; the petition stood disposed of accordingly.

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$~64

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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% Date of Decision: 12^th January, 2026

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- CRL.M.C. 222/2026 & CRL.M.A. 838/2026 & CRL.M.A. 839/2026 ABHISHEK KUMAR & ORS.

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.....Petitioner Through: Mr. Ravi Bhushan, Advocate through V.C.

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versus

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THE STATE GOVT OF NCT OF DELHI & ANR.

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.....Respondent Through: Mr. Sunil Kumar Gautam, APP for the State with SI Sachin Kumar. Mr. Dinesh Kumar Chawla, Advocate for R-2 along with respondent No.2 in person.

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CORAM:

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HON'BLE MR. JUSTICE MANOJ JAIN J U D G M E N T (oral)

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Petitioners herein seek quashing of FIR No. 1357/2015 dated 21.12.2020, registered at P.S. Amar Colony, under Section 406 IPC, along with consequential proceedings arising therefrom, based on compromise arrived at between the parties.

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Respondent no.2 was married to petitioner no.1 on 28.06.2012 as per Hindu rites and ceremonies.

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It is submitted that another FIR was also registered bearing No. 85/2014 at P.S. Dumra, District Sitamarhi, for commission of offence under Section 498A IPC as well as under Sections 3, 4 of the Dowry Prohibition Act, 1961. Admittedly, the abovesaid case resulted in conviction, fact remains that in view of the compromise, even the said proceedings stand quashed by the High Court of Judicature at Patna in Criminal Revision No. 101/2021 vide

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CRL.M.C. 222/2026 1

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Signature Not Verified Digitally Signed By:SONIA THAPLIYAL Signing Da te:1 4.01.2026 11:01:17

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order dated 23.08.2022.

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The parties have, even, obtained a decree of divorce vide judgment dated 28.06.2021.

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Parties are present through video-conferencing and the Court has interacted with them.

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Upon query to respondent No.2, she submits that she is a a practicing Advocate and has entered into the settlement voluntarily, and without any undue influence or coercion. She further states that she has also received the entire settlement amount of Rs. 30 lacs in lieu of maintenance, istridhan , alimony and therefore, would have no objection if the FIR in question is quashed.

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There is no off-spring from the wedlock in question.

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The charge-sheet has reportedly been filed, however, charges have not been ascertained yet.

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Petitioner No.1-Mr. Abhishek Kumar is, reportedly, working in Kolkata and has joined the proceedings through video-conferencing.

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His mother (petitioner No.3) is stated to be unwell and, therefore, has been taken to hospital and resultantly, his parents are unable to join the proceedings.

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The Investigating Officer (I.O.) is present and confirms the broad facts and identifies the complainant.

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In view of the settlement arrived at between the parties, continuing with criminal proceedings would serve no useful purpose, especially, when dispute does not involve any public interest and is private in nature. In any case, even the complainant does not wish to press any charges against the petitioners.

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Accordingly, exercising inherent powers vested in this Court under

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Signature Not Verified Digitally Signed By:SONIA THAPLIYAL Signing Da te:1 4.01.2026 11:01:17

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CRL.M.C. 222/2026 2

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Section 528 of the BNSS, it is deemed appropriate to quash the instant FIR. 14. Consequently, to secure the ends of justice, FIR No. 1357/2015 dated 21.12.2020, registered at P.S. Amar Colony, under Section 406 IPC, along with all consequential proceedings emanating therefrom, is hereby, quashed. 15. The petition stands disposed of in aforesaid terms.

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(MANOJ JAIN) JUDGE

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JANUARY 12, 2026/ss/sa

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Signature Not Verified

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CRL.M.C. 222/2026 3

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Digitally Signed By:SONIA THAPLIYAL Signing Da te:1 4.01.2026 11:01:17

Abhishek Kumar & Ors. v. the State Govt of NCT of Delhi & Anr.

Case brief

What is this about?

What did the court decide?

Abhishek Kumar & Ors. v. the State Govt of NCT of Delhi & Anr.

Case brief

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What the court decided

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