Allowed

Anil Sati and Ors. v. State of Uttarakhand

Uttarakhand HC2 Apr 2026C528/580/2026

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What is this about?

Matrimonial dispute case under Sections 323, 498-A IPC and Sections 3/4 Dowry Prohibition Act was settled by mutual agreement with a mutual-consent divorce petition filed. On the wife's voluntary consent and payment of part settlement amount, the High Court quashed the chargesheet, cognizance order and entire proceedings.

What did the court decide?

Chargesheet, cognizance/summoning order dated 22.04.2025 and entire criminal proceedings in Criminal Case No.2600 of 2025 quashed in terms of the compromise.

Anil Sati and Ors. Vs State of Uttarakhand — Dowry and Cruelty | Uttarakhand HC (2026)

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SL. No.	Date	Office Notes, reports, orders or proceedings or directions and Registrar’s order with Signatures	COURT’S OR JUDGE’S ORDERS
			C528/580/2026 Hon’ble Alok Mahra, J. Mr. Nalin Saun, learned counsel for the applicants.
			2. Mr. V.S. Pal, learned A.G.A. for the State.
			3. Mr. Gaurav Paliwal, learned counsel for respondent no.2/complainant. 4. Present C-528 application has been filed seeking quashing of the impugned chargesheet, cognizance/summoning order dated 22.04.2025 passed by the learned 1^st Additional Chief Judicial Magistrate, Dehradun in Criminal Case No.2600 of 2025, arising out of offences under Sections 323, 498-A I.P.C. and Section 3/4 of the Dowry Prohibition Act, along with the entire proceedings of the said criminal case. 5. Learned counsel for the applicants would submit that the dispute in question emanates from matrimonial discord between applicant no.1 (husband) and respondent no.2 (wife). Applicant nos.2 and 3 are father-in-law and mother-in-law of respondent no.2. It is contended that due to certain matrimonial differences, respondent no.2 lodged an F.I.R. under Sections 498-A, 323 I.P.C., and Section 3/4 of the Dowry Prohibition Act; that, Investigating Officer after completion of investigation has submitted chargesheet, upon which, learned trial court has taken cognizance. 6. It is further submitted that with the intervention of respectable persons and familymembers, theparties have amicably

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resolved all their disputes. They have decided to dissolve their marriage by mutual consent and have filed the first motion petition under Section 27 of the Uniform Civil Code, Uttarakhand. As per the settlement, applicant no.1 has agreed to pay a total sum of ₹6,50,000/to respondent no.2 towards full and final settlement, and the parties have also agreed to withdraw all the cases pending against each other. Out of the aforesaid settled amount, a sum of ₹3,00,000/- has already been paid to respondent no.2 at the time of first motion, and the remaining amount shall be paid at the time of filing of evidence. 7. The applicants and respondent no.2 are present through Video Conferencing before the Court and have been duly identified by their respective counsel. On being interacted with, respondent no.2 has categorically stated that the compromise has been entered into voluntarily, without any coercion or undue influence; that she has received ₹3,00,000/-; and that she has no objection if the criminal proceedings in question are quashed. 8. This Court has considered the submissions of learned counsel for the parties and perused the material available on record. The offences alleged are under Sections 498-A, 323 I.P.C. and Section 3/4 of the Dowry Prohibition Act. Though certain offences are non-compoundable under Section 320 Cr.P.C., the dispute admittedly arises out of a matrimonial relationship and is personal in nature, without any element of public interest or societal impact.

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9. The legal position with regard to
quashing of criminal proceedings on the
basis of compromise is no longer res integra. In Gian Singh v. State of Punjab, the Hon’ble Supreme Court authoritatively held that the High Court, in exercise of its inherent powers under Section 482 Cr.P.C., can quash criminal proceedings even in respect of non-compoundable offences, where the dispute is essentially private and personal in nature and the parties have amicably settled the matter, provided that the offences do not have serious impact on society. 10. In Narinder Singh v. State of Punjab, the Hon’ble Supreme Court laid down broad
guidelines for quashing on the basis of
compromise and observed that criminal
cases having overwhelmingly and
predominantly civil character, particularly those arising out of matrimonial or family disputes, should be quashed when the
parties have resolved their entire dispute, so as to secure the ends of justice.
11. Further, in State of Madhya Pradesh
v. Laxmi Narayan, the Hon’ble Supreme Court reiterated that criminal proceedings
arising out of matrimonial disputes and family matters, which have been amicably
settled, can be quashed in exercise of
inherent jurisdiction, unless the offences are heinous and of serious mental
depravity. More recently, in Parbatbhai
Aahir v. State of Gujarat, the Hon’ble
Supreme Court summarized the principles
governing exercise of power under Section
482 Cr.P.C., holding that the High Court
must evaluate whether continuation of
proceedings would amount to abuse of the

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process of law and whether quashing would secure the ends of justice. 12. In the present case, the allegations stem purely from matrimonial discord between the husband and wife. The parties have amicably settled their dispute; the first motion for mutual divorce has been filed; substantial part of the settled amount has already been paid; and respondent no.2 has unequivocally stated that she has no objection to quashing of the proceedings. There is no allegation of any heinous offence, nor is there any element affecting society at large. Continuation of criminal proceedings, in such circumstances, would serve no fruitful purpose. 13. In view of the settlement arrived at between the parties and in light of the law laid down by the Hon’ble Supreme Court in the aforesaid judgments, the compounding application is allowed. Consequently, the present C-528 application stands allowed. The impugned chargsheet, cognizance/summoning order dated 22.04.2025 passed by the learned 1^st Additional Chief Judicial Magistrate, Dehradun in Criminal Case No.2600 of 2025, arising out of offences under Sections 323, 498-A I.P.C. and Section 3/4 of the Dowry Prohibition Act as well as the entire criminal proceedings are hereby quashed the applicants in terms of the compromise arrived at between the parties. 14. Pending applications, if any, shall stand disposed of accordingly. Digitally signed by MAMTA RANI DN: c=IN, o=HIGH COURT OF UTTARAKHAND, ou=HIGH COURT OF UTTARAKHAND, 2.5.4.20=6a812005bebfcf46f244f3 MAMT e584af1449e430ef900bf09a6d67e bbd642671329b, postalCode=263001, st=Uttarakhand, serialNumber=5de1751a4f1d9cab (Alok Mahra, J.) A RANI fd54852c9e68911ca8b66dd26690 a191648ab5d8dd004ef0, cn=MAMTA RANI 02.04.2026 Mamta Date: 2026.04.06 17:14:35 +05'30'

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Anil Sati and Ors. v. State of Uttarakhand

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Anil Sati and Ors. v. State of Uttarakhand

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