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Jasmair Singh & Anr. vs The State of Haryana & Anr.

Criminal Appeal · 2022 INSC 907Decided 5 Sept 2022
Criminal Appeal No. 1444 of 2022
S. Ravindra Bhat

Background

A husband was facing prosecution under an FIR registered in 2016 at Police Station Pehowa, Kurukshetra, Haryana, for offences under Sections 323, 406, 498-A and 506 IPC (hurt, criminal breach of trust, cruelty to a wife, and criminal intimidation) arising from a matrimonial dispute. The husband and wife later entered into a compromise settling all pending litigation between them, and the husband sought quashing of the FIR under Section 482 CrPC before the Punjab & Haryana High Court, which was refused. He then appealed to the Supreme Court.

Decision Breakdown

The Supreme Court noted it was undisputed that the parties had genuinely settled their disputes. Relying on its earlier ruling in Gian Singh v. State of Punjab (2012) 10 SCC 303, which permits quashing of criminal proceedings, including certain non-compoundable matrimonial offences, where the parties have amicably resolved their differences and continuing the prosecution would serve no purpose, the Court held the case was eminently suitable for exercising quashing jurisdiction. It allowed the appeal, took the settlement on record, and quashed the FIR and all proceedings arising from it.

Lesson Learnt

Where spouses genuinely settle a matrimonial criminal dispute, courts can quash the FIR and related proceedings under Section 482 CrPC (even for offences that are not technically "compoundable") if continuing the prosecution would serve no real purpose, but this is an exercise of discretion, not an automatic right, and depends on the genuineness of the settlement and nature of the offence.

Official source (sci.gov.in)View Judgment (PDF)

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