Uttarakhand High Court quashes FIR in non compoundable matrimonial dispute following amicable settlement

The High Court exercises its inherent powers to quash criminal proceedings, citing potential abuse of process and extreme injustice due to an amicable settlement between the parties.

In a significant decision, the Uttarakhand High Court has quashed an FIR and subsequent criminal proceedings in a matrimonial dispute between Ravish Bhatt and Smt. Puja Dhoundiyal. The decision, delivered by Justice Pankaj Purohit on November 17, 2025, underscores the court's ability to exercise its inherent powers to ensure justice and prevent abuse of the legal process, even in cases involving non-compoundable offences.

The case, originating from FIR No.0202 of 2022, involved charges under Sections 498A, 323, 504, and 506 of the Indian Penal Code, as well as Sections 3/4 of the Dowry Prohibition Act, 1961. These charges were initially filed with the Police Station Raipur in Dehradun and were pending before the Additional Civil Judge (Senior Division).

The court's decision came after both parties submitted a joint compounding application, supported by affidavits, indicating that they had settled their differences amicably. The applicant, Ravish Bhatt, and respondent No. 2, Smt. Puja Dhoundiyal, were present in court, with the latter participating via video conferencing. Both parties confirmed their intention to resolve their disputes through mutual consent, further evidenced by their filing for a mutual divorce under Section 13B of the Hindu Marriage Act, 1955.

The High Court, while considering the compounding application, acknowledged the Supreme Court's precedents in B.S. Joshi v. State of Haryana and Gian Singh v. State of Punjab, which allow the quashing of criminal proceedings in cases where an amicable settlement renders the possibility of conviction remote and continuing the proceedings would result in oppression and injustice.

Justice Purohit emphasized that the inherent powers of the High Court are distinct from the statutory powers for compounding offences and are to be exercised to secure the ends of justice or to prevent abuse of the court's process. The judgment asserted that continuation of the proceedings in light of the settlement would indeed be contrary to the interests of justice.

Consequently, the court allowed the compounding application and quashed the FIR and all related proceedings, including the charge sheet dated November 4, 2022. This ruling is expected to have a significant impact on similar matrimonial disputes, highlighting the judiciary's role in facilitating amicable resolutions and reducing unnecessary legal burdens when the involved parties have mutually agreed to settle their differences.

Bottom Line:

High Court can quash criminal proceedings or FIR in exercise of its inherent powers under Section 482 Cr.P.C. (Section 528 of BNSS) even for non-compoundable offences if the parties have amicably settled the dispute and continuation of proceedings would amount to abuse of process of law.

Statutory provision(s): Criminal Procedure Code, 1973 Section 482 (Section 528 of BNSS), Dowry Prohibition Act, 1961 Sections 3/4, Indian Penal Code, 1860 Sections 498A, 323, 504, 506.

Ravish Bhatt v. State Of Uttarakhand, (Uttarakhand) : Law Finder Doc Id # 2809646