Sagar Bharti & Ors. vs. The State (NCT) of Delhi & Anr.

Writ Petition (Criminal) · CNR No. DLHC010156892026Decided 13 Oct 2026New Delhi Bench
W.P.(CRL) 1217/2026CNR: DLHC010156892026
Justice Girish Kathpalia

Background

An FIR had been registered against the petitioners (the husband and his relatives) alleging cruelty, criminal breach of trust and related offences under Sections 498A/406/34 IPC. The couple's marriage had already ended in divorce, with no children from the marriage. The complainant (the wife) and the petitioners later reached a full settlement, under which she received her complete stridhan (personal/marital property given to a bride) and maintenance dues.

Decision Breakdown

The complainant appeared in court, was identified by the investigating officer, and personally confirmed to the judge (in Hindi) that she had compromised all disputes, received full payment, and no longer wished to pursue the case. The State also had no objection. Finding it in the interest of justice not to force the parties through a full trial once a genuine settlement was reached, the Court quashed the FIR and all related proceedings.

Lesson Learnt

Courts can quash a criminal case in a matrimonial dispute once both sides have genuinely and voluntarily settled, provided the complainant personally confirms the compromise in court, sparing both families a lengthy and often needless trial.

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The Court confirmed that Rs. 20 lakh had already been paid and the remaining Rs. 10 lakh was handed over (and accepted) in court via demand draft. Speaking directly with the wife, the judge confirmed she entered the settlement voluntarily and no longer wished to pursue the case; the State also raised no serious objection. Relying on Supreme Court precedent (Jitendra Raghuvanshi v. Babita Raghuvanshi, (2013) 4 SCC 58), which holds that High Courts can quash even non-compoundable offences in matrimonial disputes to encourage genuine settlements, the Court quashed the FIR and all related proceedings.

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Dharmender Kumar Tandon vs. The State of NCT of Delhi

Given the petitioner's long incarceration and good conduct record, and with the State's consent, the Court allowed the petition and set aside the earlier order rejecting parole. It granted parole for four weeks (not the full two months requested), conditioned on the petitioner furnishing a personal bond of Rs. 10,000 with one surety of the same amount, with the Jail Superintendent to formally inform him in writing of his exact surrender date after the parole period ends.

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Vishal Sharma & Ors. vs. The State Through SHO & Anr.

The State had no objection, and the complainant personally appeared in court, was identified by the investigating officer, and confirmed in Hindi that he had genuinely settled all disputes with the petitioners and no longer wished to pursue the case. Satisfied that the parties were now living peacefully as neighbours and that forcing a full trial would serve no purpose, the Court exercised its inherent power to quash the FIR and all proceedings arising from it.

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Rupesh Saini vs. The State GNCT (Delhi) & Anr.

The wife appeared via videoconferencing, was identified by the investigating officer, and personally told the judge (in Hindi) that she had settled all disputes and received full payment. The State raised no objection. Satisfied this was a genuine settlement and that forcing a full trial would serve no purpose, the Court allowed the petition and quashed the FIR along with all related proceedings.

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