Ravi v. The State Of Tamilnadu

BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT Dated : 19.02.2026

CORAM

THE HONOURABLE MRS. JUSTICE L. VICTORIA GOWRI CRL OP(MD). No.3584 of 2026 Ravi ... Petitioner/Sole Accused Vs

1. The State of Tamilnadu Rep by, The Inspector of Police, All Women Police Station, Sivagangai, Sivagangai District.

(In Crime No.23 of 2020) ... 1st Respondent/Complainant 2.The Village Welfare Officer, Social Welfare Officer, Sivagangai.

... 2nd Respondent/Defacto Complainant 3.xxxxxx xxxxxx xxxxxx ... 3rd Respondent/Victim PRAYER : Criminal Original Petition is filed under Section 528 of BNSS, 2023, to call for the records pertaining to the charge sheet in C.C.No.81 of 2025 on the file of the Additional Mahila Court (Judicial Magistrate), Sivagangai, and quash the same as illegal. 1/8

For Petitioner : Mr.A.V.Arun For R1 : Mr.B.Thanga Aravindh Government Advocate (Crl.Side) For R3 : Mr.S.Sumitha

ORDER

This Criminal Original Petition is filed under Section 482 CrPC / Section 528 BNSS, seeking to quash the charge sheet in C.C.No.81 of 2025 on the file of the Additional Mahila Court (Judicial Magistrate), Sivagangai.

2. The gist of the allegations in the final report is that, the petitioner performed a child marriage with the victim on 06.12.2020. Pursuant to the complaint given by the defacto complainant / second respondent, a case in Crime No.23 of 2020 was registered on the file of the first respondent against the petitioner for the offences under Sections 9 & 10 of the Prohibition of Child Marriage Act, 2006 and the same culminated in laying final report in C.C.No.81 of 2025 before the Additional Mahila Court (Judicial Magistrate), Sivagangai, for the same offence. Seeking quashment of the charge sheet, this Criminal Original Petition is filed.

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3. Admittedly, the Sub Registrar, Melur East, issued a marriage certificate dated 06.01.2026 vide Marriage Sl.No.TMR/Melur (East)2/2026 certifying that the marriage between the petitioner and the third respondent/victim girl has been solemnized on 06.01.2026 and the same has been registered on the same day itself at serial No.2 of Register of Marriages maintained under the Tamilnadu Registration of Marriages Act, 2009 and the parties have now resolved the dispute amicably. It is also stated that the petitioner and the second respondent/victim are leading matrimonial life peacefully. A Joint Compromise Memo dated 18.02.2026 has been filed before this Court.

4.

The petitioner and the victim are present before this Court in person and are identified by Mrs.M.Selvi, Women Special Sub-Inspector of Police, All Women Police Station, Sivagangai, Sivagangai District. The Victim has categorically stated that she do not wish to pursue the proceedings against the petitioner herein. This Court is satisfied that the compromise is voluntary and not the result of any coercion or undue influence.

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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 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 2012 (10) SCC 303 2017 (9) SCC 641 4/8

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. 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 2019 (5) SCC 688 5/8

allegations, the relationship between the parties, the conduct of the petitioner, the stage of the proceedings, and the voluntary nature of the compromise.

9.

The dispute in question is predominantly private in character 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 charge sheet in C.C.No.81 of 2025 on the file of the Additional Mahila Court (Judicial Magistrate), Sivagangai, is quashed and the Criminal Original Petition stands allowed. The petitioner shall pay a sum of Rs.5,000/- (Rupees Five Thousand only) for establishing an E-Library to the credit of the MBHAA, in Indian Bank, Madurai Bench of Madras High Court Branch, Account No.496038755 IFSC No.IDIB000H040, MICR Code: 625019020, on or before 10.04.2026. The joint compromise memo dated 18.02.2026 shall form part and parcel of this order. 6/8

11.

The petitioner is directed to file a memo along with the photocopy of the receipt before the Registry on or before 10.04.2026. List the matter on 15.04.2026, for reporting compliance. 19.02.2026 NCC : Yes/No Index : Yes/No dss TO 1.The Additional Mahila Court (Judicial Magistrate), Sivagangai.

2. The Inspector of Police, All Women Police Station, Sivagangai, Sivagangai District.

3.The Additional Public Prosecutor, Madurai Bench of Madras High Court, Madurai.

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L. VICTORIA GOWRI,J dss

ORDER

IN CRL OP(MD). No.3584 of 2026 Date : 19.02.2026 8/8