The Supreme Court, exercising its inherent powers under Section 482 CrPC, quashed criminal proceedings—including a non-compoundable offense under Section 376 IPC—based on an amicable settlement between the parties. The Court emphasized that while such offenses are grave, exceptional circumstances (victim’s unequivocal settlement, societal harmony, and futility of trial) justified judicial intervention to prevent abuse of process. The ruling reaffirms that ends of justice override rigid legal constraints in unique cases.
Facts Of The Case:
The case arose from two FIRs registered in November 2023 at Mehunbare Police Station, Jalgaon. The first FIR (No. 302/2023) was filed against Madhukar and others under Sections 324, 143, 147, 452, and others of the IPC, alleging they assaulted a woman and her family due to a prior dispute involving her father, Prabhakar. The second FIR (No. 304/2023), lodged a day later, accused Prabhakar of rape (Section 376 IPC), sexual harassment, and criminal intimidation, claiming he had exploited the complainant, recorded videos, and disrupted her marriage prospects.In March 2024, the complainant in the rape case filed an affidavit before the Bombay High Court, stating she had settled the matter amicably, received ₹5 lakhs for marriage expenses, and no longer wished to pursue the case. The accused sought quashing of both FIRs under Section 482 CrPC, but the High Court refused, citing the non-compoundable nature of Section 376 IPC.On appeal, the Supreme Court noted the unusual timing of the FIRs (suggesting a retaliatory motive) and the complainant’s clear stance—now married and unwilling to continue prosecution. Balancing the gravity of the offense with the settlement’s genuineness, the Court quashed the proceedings, holding that continuing the trial would serve no useful purpose and cause further distress. The judgment highlights the discretionary power of courts to ensure justice in exceptional cases.
Procedural History:
The procedural history of the case began with the registration of two FIRs in November 2023 at Mehunbare Police Station, Jalgaon. The first FIR (No. 302/2023) was filed against Madhukar and others for assault and unlawful assembly, while the second FIR (No. 304/2023) accused Prabhakar of rape and sexual offenses. The cases progressed to the trial court, where Sessions Case No. 29/2024 was initiated for the rape charges.In March 2024, the complainant filed an affidavit before the Bombay High Court (Aurangabad Bench), expressing her desire to withdraw the case due to an amicable settlement. The accused then filed Criminal Applications Nos. 2561 and 2185 of 2024 under Section 482 CrPC, seeking quashing of both FIRs. However, the High Court, in its order dated 07.03.2025, dismissed the applications, ruling that non-compoundable offenses like rape (Section 376 IPC) could not be quashed solely based on a settlement.Aggrieved by this decision, the appellants approached the Supreme Court via Special Leave Petitions (SLP(Crl) Nos. 7212 & 7495 of 2025). After granting leave, the Court examined the peculiar facts, including the timing of the FIRs and the complainant’s unequivocal stance, and ultimately quashed the proceedings in its judgment dated 14.07.2025, prioritizing the ends of justice over procedural rigidity.
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Court Observation:
In its judgment, the Supreme Court made several key observations while quashing the criminal proceedings. The Court acknowledged the grave nature of offenses under Section 376 IPC and reiterated that such non-compoundable charges are generally not quashed based on settlements. However, it emphasized that the inherent powers under Section 482 CrPC are meant to secure the ends of justice and must be exercised in exceptional cases.The Court noted the peculiar circumstances of the case, including the timing of the second FIR—filed just a day after the first—which suggested a retaliatory motive. It also highlighted the complainant’s unequivocal stance, as she had settled the matter, received compensation, and was now married, with no intention to pursue the case further. The Court observed that continuing the trial would serve no meaningful purpose and would only cause further distress to the parties, particularly the complainant, whose life had moved on.While reaffirming that heinous crimes like rape should ordinarily be prosecuted rigorously, the Court held that in this unique factual matrix, quashing the proceedings was necessary to prevent an abuse of the judicial process. The judgment underscored the discretionary power of courts to balance legal principles with the realities of human relationships and societal harmony.
Final Decision & Judgement:
The Supreme Court allowed the appeals and set aside the Bombay High Court’s order dated 07.03.2025, quashing FIR No. 302 of 2023 (assault case) and FIR No. 304 of 2023 (rape case) along with all connected proceedings, including Sessions Case No. 29 of 2024. In its final decision dated 14.07.2025, the Bench comprising Justices Vikram Nath and Sanjay Kumar exercised its inherent powers under Section 482 CrPC to prevent abuse of the judicial process, holding that continuing the prosecution would be futile and unjust under the extraordinary circumstances of the case.The Court ruled that while Section 376 IPC offenses are non-compoundable and normally require strict prosecution, the exceptional factors in this case – including the complainant’s settled marital life, genuine settlement, and her categorical withdrawal of allegations – justified judicial intervention to secure the ends of justice. The judgment clarified that this decision does not set a precedent for routine quashing of serious offenses, but rather demonstrates the judiciary’s flexibility in unique cases where technical rigors of law must yield to overarching justice. All pending applications were disposed of accordingly.
Case Details:
Case Title: Madhukar & Ors. vs. The State of Maharashtra & Anr. along with Prabhakar vs. The State of Maharashtra & Anr. Citation: 2025 INSC 819 Criminal Appeal No.: (Arising out of SLP(Crl.) No. 7212 of 2025) Date of Judgment: July 14, 2025 Judges/Justice Name: Justice Vikram Nath & Justice Sanjay Kumar
Download The Judgement Here