Bhuvaneswari v. State Of Tamilnadu Rep By Inspector Of Police, Anna Nagar
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED : 08.01.2026
CORAM
THE HONOURABLE MRS.JUSTICE L.VICTORIA GOWRI 1.Bhuvaneswari 2.Boominathan 3.Maruthavalli ... Petitioners/A1 - A3 Vs.
1.The State of Tamil Nadu, Rep.by its Inspector of Police, Anna Nagar Police Station, Madurai City - 625 020.
(Crime No.302/2023) ... Respondent/Complainant 2.Senthil ... Respondent/Defacto Complainant Prayer : Criminal Original Petition is filed under Section 528 of BNSS, 2023, to call for the entire records relating to the S.T.C.No.486/2024 on the file of the Learned Judicial Magistrate Court No.VI, Madurai and quash the same as illegal.
For Petitioner : Mr.S.Balasubramanian For R1 : Mr.S.Ravi Additional Public Prosecutor 1/8
ORDER
This Criminal Original Petition is filed under Section 482 CrPC / Section 528 BNSS, seeking to quash the final report in S.T.C.No.486 of 2024 on the file of the Learned Judicial Magistrate Court No.VI, Madurai, insofar as the petitioners are concerned.
2. The case of the prosecution is that the defacto complainant, had filed a divorce petition before the Family Court, Madurai, which was referred to mediation. On 10.05.2023, during the mediation proceedings at the Mediation Centre, the defacto complainant and the petitioners were present. It is alleged that subsequent to the mediation, the petitioners abused and criminally intimidated the defacto complainant. Based on the complaint lodged by the defacto complainant, the 1st respondent police registered FIR in Crime No.302 of 2023 for the offences under Sections 294(b), 323 and 506(i) of IPC which culminated in filing final report in S.T.C.No.338 of 2024 on the file of the learned Judicial Magistrate Court No.VI, Madurai for the offences under Sections 34, 294(b), 323 and 506(i) of IPC. 2/8
3. Admittedly, the petitioners and the 2nd respondent are relatives and they have now resolved the dispute amicably. A Joint Compromise Memo dated 08.01.2026 has been filed before this Court.
4. The petitioners and the 2nd respondent / defacto complainant are present before this Court in person and are identified by Mr.G.Krishnan, SSI, Anna Nagar Police Station, Madurai City. The defacto complainant has categorically stated that he does not wish to pursue the FIR against the petitioners. This Court is satisfied that the compromise is voluntary and not the result of any coercion or undue influence.
5. The law relating to quashment of criminal proceedings on the basis of compromise between the parties is well settled. In Gian Singh v. State of Punjab1, the Hon'ble Supreme Court authoritatively held that the inherent power of the High Court under Section 482 CrPC is of 1 2012 10 SCC 303 3/8
wide amplitude and may be exercised to quash criminal proceedings even in respect of non-compoundable offences, provided the dispute is essentially private in nature and the quashment would secure the ends of justice. The Court, however, drew a clear distinction between offences arising out of personal or matrimonial disputes, commercial transactions and similar private wrongs, and serious or heinous offences having grave impact on society, holding that the latter category cannot ordinarily be quashed merely on the basis of a settlement.
6. The said principles were succinctly crystallised in Parbatbhai Aahir v. State of Gujarat2, wherein the Supreme Court, after surveying the earlier precedents, laid down broad propositions governing the exercise of inherent jurisdiction on the basis of compromise. It was emphasised that the paramount consideration is whether the continuance of the criminal proceedings would be unfair or contrary to the interests of justice, and whether the dispute predominantly bears a civil or private character, rendering the possibility of conviction remote and bleak.
2 (2017) 9 SCC 641 4/8
7. In State of Madhya Pradesh v. Laxmi Narayan3, the Supreme Court reiterated and clarified the limitations on such power, holding that offences of a serious nature, particularly those involving mental depravity, grave violence, or offences against society at large, cannot be quashed on the basis of compromise, even if the parties have amicably settled the dispute. The Court further cautioned that while examining compromise quash petitions, the High Court must consider the nature and gravity of the offence, the conduct of the accused, and the stage of the proceedings, and the overall impact on society and must satisfy itself that the settlement is voluntary and not the result of coercion or undue influence.
8. Applying the aforesaid principles to the facts of the present case, this Court has carefully examined the nature and gravity of the allegations, the relationship between the parties, the conduct of the petitioners, the stage of the proceedings, and the voluntary nature of the compromise.
3 (2019) 5 SCC 688 5/8
9. The dispute in question is predominantly family dispute and does not involve any offence having serious or grave impact on society at large. In view of the compromise arrived at between the parties, the possibility of conviction is rendered remote and bleak. Continuation of the criminal proceedings would therefore serve no useful purpose and would amount to an abuse of the process of Court.
10. Accordingly, the impugned Final Report in S.T.C.No.486 of 2024 on the file of the learned Judicial Magistrate Court No.VI, Madurai is quashed and the Criminal Original Petition stands allowed subject to the condition that each of the petitioners shall deposit an amount of Rs.3,000/- to the District Legal Services Authority, Madurai District. The joint compromise memo dated 08.01.2026 shall form part and parcel of this order.
11. The petitioners are directed to file a memo along with the photocopy of the receipt before the Registry on or before 13.02.2026. In 6/8
the event of non-compliance with the order passed by this Court, the same shall stand automatically vacated. List the matter on 16.02.2026 for reporting compliance.
08.01.2026 NCC : Yes / No Index : Yes / No Internet : Yes/ No gbg To 1.The Inspector of Police, Anna Nagar Police Station, Madurai City - 625 020.
2.The District Legal Services Authority, Madurai District.
3. The Additional Public Prosecutor, Madurai Bench of Madras High Court, Madurai.
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L.VICTORIA GOWRI, J.
gbg 08.01.2026 8/8