Allowed¶55

Sh. Virender Verma and Others v. the State Govt. of NCT of Delhi and Anr.

Delhi HC17 Jul 2026CRL.M.C./8629/2025

Case brief

AI extract

What is this about?

Quashing of FIR on settlement; matrimonial dispute; Sections 498A/406/34 IPC; Section 528 BNSS; Section 482 CrPC inherent power; non-compoundable offence quashed on compromise; Gian Singh (2012) 10 SCC 303; Narinder Singh (2014) 6 SCC 466; mutual consent divorce decree; stridhan, dowry articles, maintenance; LIC bond; instalments; CRL.M.C. 8629/2025; PS Jait Pur; Delhi High Court; Prateek Jalan; 2026.

What did the court decide?

Quashing of FIR No. 521/2018 dated 27.08.2018 registered at Police Station Jait Pur, District South East, Delhi, under Sections 498A/406/34 IPC, alongwith all consequential proceedings arising therefrom; parties bound by the terms of the settlement; petition alongwith any pending applications disposed of. ¶55

Sh. Virender Verma and Others Vs the State Govt. of NCT of… — Dowry and Cruelty | Delhi HC (2026)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether FIR No. 521/2018 dated 27.08.2018 registered at Police Station Jait Pur under Sections 498A/406/34 IPC, and all proceedings emanating therefrom, should be quashed under Section 528 BNSS on the ground of settlement between the parties. +1 more

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Court's answer

In exercise of powers under Section 528 BNSS (corresponding to Section 482 CrPC), the High Courts can quash criminal proceedings even with respect to non-compoundable offences on the ground of compromise between the accused and the complainant, especially when no overarching public interest is adversely affected.

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Ratio / Principle

The proceedings arise out of a matrimonial relationship already culminated in a decree of divorce; respondent No. 2 categorically affirmed the voluntary nature of the settlement; applying the tests laid down by the Supreme Court, the criminal proceedings are unlikely to result in conviction and their continuation would be an empty formality.

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Key takeaways

With the balance settlement amount of Rs.2,00,000/- handed over to respondent No. 2 in Court, there is no impediment in granting the relief sought.ratio¶54
The petition is allowed; FIR No. 521/2018 dated 27.08.2018 registered at Police Station Jait Pur, District South East, Delhi, under Sections 498A/406/34 IPC, alongwith all consequential proceedings arising therefrom, is hereby quashed.ratio¶55
The parties shall remain bound by the terms of the settlement.ratio

Detailed headnote1 paragraphs

Delhi High Court (Prateek Jalan, J.), by order dated 17.07.2026 in CRL.M.C. 8629/2025 under Section 528 BNSS (corresponding to Section 482 CrPC), allowed the petition and quashed FIR No. 521/2018 dated 27.08.2018 of Police Station Jait Pur, District South East, Delhi, under Sections 498A/406/34 IPC, alongwith all consequential proceedings, on the ground of settlement. Petitioner No. 1 and respondent No. 2, married on 05.12.2006 and living separately since 06.03.2018, resolved all disputes by a Settlement Agreement dated 06.08.2025 under the aegis of the Counselling Cell, Family Courts, Saket, whereby the marriage was dissolved by a mutual-consent divorce decree dated 13.11.2025; petitioner No. 1 was to pay Rs.5,70,000/- alongwith an LIC bond towards full and final settlement of all claims including stridhan, dowry articles and maintenance, of which Rs.3,70,000/- had been received and the balance Rs.2,00,000/- was handed over in Court. Relying on Gian Singh v. State of Punjab & Anr., (2012) 10 SCC 303, and Narinder Singh & Ors. v. State of Punjab & Anr., (2014) 6 SCC 466, the Court held that criminal cases of overwhelmingly and predominantly civil character arising out of matrimonial disputes may be quashed on settlement where conviction is unlikely; finding the settlement voluntary and its continuation an empty formality, it quashed the FIR and directed that the parties remain bound by the settlement terms.

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$~62 Q

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- CRL.M.C. 8629/2025

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SH. VIRENDER VERMA AND OTHERS .....Petitioners Through: Mr. R.P. Sharma, Advocate. [M:9868249612] along with Petitioners in person

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versus

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THE STATE GOVT. OF NCT OF DELHI AND ANR. .....Respondents Through: Mr. Hitesh Vali, APP. Insp. Satbir Singh, PS Jaitpur. Mr. Manbir Singh, Advocate for R-2 alongwith R-2 in Person.

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CORAM: HON’BLE MR. JUSTICE PRATEEK JALAN

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O R D E R

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% 17.07.2026

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By way of this petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 [“BNSS”] (corresponding to Section 482 of the Code of Criminal Procedure, 1973 [“CrPC”]), the petitioners seek quashing of FIR No. 521/2018, dated 27.08.2018, registered at Police Station Jait Pur, District South East, Delhi, under Sections 498A/406/34 of the Indian Penal Code, 1860 [“IPC”], and all proceedings emanating therefrom, on the ground of settlement.

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The petitioners are present in Court, and are identified by their learned counsel, as well as by the Investigating Officer. Respondent No. 2 is also present in Court, and is identified by her learned counsel and the

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CRL.M.C. 8629/2025

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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 20/07/2026 at 11:19:27

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Investigating Officer.

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The petition is taken up for disposal with the consent of learned counsel for the parties.

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Petitioner No. 1 and respondent No. 2 were married on 05.12.2006, in accordance with Hindu rites and ceremonies, and no child was born from the wedlock. Due to matrimonial discord and temperamental differences between the parties, they have been living separately since 06.03.2018.

¶19

Petitioner No. 1 was, at the relevant time, the husband of respondent No. 2, and petitioner Nos. 2 and 3 are the mother-in-law and sister-in-law of respondent No. 2, respectively.

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Respondent No. 2 lodged a formal complaint before the Crime Against Women Cell, on the basis of which the impugned FIR was registered against the petitioners herein.

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During the pendency of the proceedings, petitioner No. 1 and respondent No. 2 have amicably resolved all their disputes under the aegis of the Counselling Cell, Family Courts, Saket, South East, Delhi, by way of a Settlement Agreement dated 06.08.2025, whereby they agreed to dissolve their marriage by mutual consent. It was further agreed that petitioner No. 1 shall pay a total sum of Rs.5,70,000/- to respondent No. 2, alongwith the LIC bond standing in her name, towards full and final settlement of all her claims, including stridhan, dowry articles, and past, present and future maintenance, in three instalments. The parties further agreed that the final instalment of Rs.2,00,000/- shall be paid to her at the time of quashing of the subject FIR.

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Learned counsel for the parties confirm that the settlement has been

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CRL.M.C. 8629/2025

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Page 2 of 6

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This is a digitally signed order. 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 20/07/2026 at 11:19:27

¶26

entered into voluntarily and without any coercion or undue pressure.

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Pursuant to the settlement, the marriage has been dissolved between petitioner No. 1 and respondent No. 2, by a decree of divorce by mutual consent vide order dated 13.11.2025, passed by the Family Courts. 10. In light of the aforesaid, parties seek quashing of the impugned FIR.

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The Supreme Court has clearly held that, in certain circumstances, the High Courts, in exercise of their powers under Section 528 of BNSS (corresponding to Section 482 of CrPC), can quash criminal proceedings, even with respect to non-compoundable offences, on the ground that there is a compromise between the accused and the complainant, especially when no overarching public interest is adversely affected. 12. The Supreme Court, in Gian Singh v. State of Punjab & Anr.¹ , has held as follows:

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“ 58. Where the High Court quashes a criminal proceeding having regard to the fact that the dispute between the offender and the victim has been settled although the offences are not compoundable, it does so as in its opinion, continuation of criminal proceedings will be an exercise in futility and justice in the case demands that the dispute between the parties is put to an end and peace is restored; securing the ends of justice being the ultimate guiding factor . No doubt, crimes are acts which have harmful effect on the public and consist in wrongdoing that seriously endangers and threatens the well-being of the society and it is not safe to leave the crime-doer only because he and the victim have settled the dispute amicably or that the victim has been paid compensation, yet certain crimes have been made compoundable in law, with or without the permission of the court. In respect of serious offences like murder, rape, dacoity, etc., or other offences of mental depravity under IPC or offences of moral turpitude under special statutes, like the Prevention of Corruption Act or the offences committed by public servants while working in that capacity, the settlement between the offender and the victim can have no legal

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1 (2012) 10 SCC 303.

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CRL.M.C. 8629/2025

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Page 3 of 6

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This is a digitally signed order.

¶34

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 20/07/2026 at 11:19:27

¶35

sanction at all. However, certain offences which overwhelmingly and predominantly bear civil flavour having arisen out of civil, mercantile, commercial, financial, partnership or such like transactions or the offences arising out of matrimony, particularly relating to dowry, etc. or the family dispute, where the wrong is basically to the victim and the offender and the victim have settled all disputes between them amicably, irrespective of the fact that such offences have not been made compoundable, the High Court may within the framework of its inherent power, quash the criminal proceeding or criminal complaint or FIR if it is satisfied that on the face of such settlement, there is hardly any likelihood of the offender being convicted and by not quashing the criminal proceedings, justice shall be casualty and ends of justice shall be defeated . The above list is illustrative and not exhaustive. Each case will depend on its own facts and no hard-andfast category can be prescribed. ”²

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Further, in Narinder Singh & Ors. v. State of Punjab & Anr.³ the Supreme Court has also 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:

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2 Emphasis supplied.

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3 (2014) 6 SCC 466.

CRL.M.C. 8629/2025

Page 4 of 6

(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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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 .”⁴

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In the present case, the proceedings between the parties arise out of a matrimonial relationship, which has already culminated in a decree of divorce. Applying the tests laid down by the Supreme Court, it may be observed that the respondent No. 2 has also categorically affirmed the voluntary nature of the settlement before the Court. In these circumstances, the criminal proceedings are unlikely to result in conviction, and its continuation would be an empty formality, adding to the burden of the justice system and consuming public resources unnecessarily.

CRL.M.C. 8629/2025

Page 5 of 6

The settlement contemplates payment of a sum of Rs. 5,70,000/- to respondent No. 2, out of which Rs. 3,70,000/- has already been received by her. The balance amount, i.e. Rs.2,00,000/-, has been handed over to respondent No. 2 in Court today. There is therefore no impediment in granting the relief sought.

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Having regard to the above discussion, the petition is allowed, and FIR No. 521/2018, dated 27.08.2018, registered at Police Station Jait Pur, District South East, Delhi, under Sections 498A/406/34 of the IPC, alongwith all consequential proceedings arising therefrom, is hereby quashed.

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The parties shall remain bound by the terms of the settlement.

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The petition, alongwith any pending applications, accordingly stands disposed of.

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PRATEEK JALAN, J

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JULY 17, 2026 ‘pv’/mk/

4 Emphasis supplied.

CRL.M.C. 8629/2025

Page 6 of 6

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 20/07/2026 at 11:19:27

Sh. Virender Verma and Others v. the State Govt. of NCT of Delhi and Anr.

Case brief

What is this about?

What did the court decide?

Sh. Virender Verma and Others v. the State Govt. of NCT of Delhi and Anr.

Case brief

What is this about?

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Why is it important?

What the court decided

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