The Orissa High Court has quashed the entire criminal proceedings initiated against a woman in connection with Udit Nagar P.S. Case No.64 of 2016 corresponding to G.R. Case No.371 of 2016 pending before the Court of learned S.D.J.M.(P), Rourkela, after the parties amicably settled their matrimonial dispute. Dr. Justice Sanjeeb Kumar Panigrahi, while exercising the inherent power under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, allowed the CRLMC petition filed by Manjit @ Mandeep Kaur and observed that prolonged adversarial litigation in matrimonial matters not only aggravates bitterness between the parties but also results in unnecessary consumption of judicial time. The Court noted that the prosecution case stemmed from a complaint filed by the opposite party No.2 on 12.03.2016 alleging that she had been brutally assaulted by her mother-in-law, sister-in-law and brother-in-law on 11.03.2016 and again on the next day, resulting in bleeding injuries, leading to registration of the case under Sections 498-A, 323, 354, 506 and 34 of the IPC.
Learned counsel for the respective parties submitted before the Court that in the interregnum the dispute between the parties has been amicably settled with the help of family members and village gentries. In support thereof, a joint affidavit dated 07.04.2026 was filed in Court, which was taken on record. The relevant portion of the joint affidavit stated that during the pendency of the CRLMC application both parties have settled their dispute amicably and the opposite party No.2 is staying with her husband separately from her in-laws members. In view of the development she does not want to proceed with the case any further and they have no objection if the criminal proceeding is quashed. The affidavit further stated that the joint affidavit was filed without any fear, threat or coercion from any corner and both parties would suffer irreparable loss and injuries if the criminal proceeding is allowed to continue.
The learned counsel for the State as well as the learned counsel for the opposite party No.2 submitted that looking to the overall circumstances and since the parties have amicably settled the matter amongst themselves and are no longer interested in supporting the prosecution, no useful purpose will be served in continuing with these proceedings. The Court, relying upon the decisions of the Supreme Court in Gian Singh v. State of Punjab, Narinder Singh & Ors. v. State of Punjab & Anr. and B.S. Joshi & Ors. v. State of Haryana & Anr., held that when the parties have reached a settlement and on that basis a petition for quashing the criminal proceedings is filed, the guiding factor would be to secure the ends of justice or to prevent abuse of the process of any Court. The Court observed that in matrimonial disputes a pragmatic and humane approach is required, keeping in view the delicate nature of such relationships and their impact on the social fabric. It further noted that efforts ought to be made to encourage reconciliation and amicable settlement between the parties so as to enable them to reflect upon their respective shortcomings and resolve their disputes through mutual consent.
In light of the aforesaid settled position of law and having regard to the facts of the case, the Court was of the considered opinion that the aim and object of the legal system is not merely to punish the offender, but equally to preserve and promote peace, tranquillity and harmony in society. Consequently, the Court allowed the application and quashed the entire criminal proceeding initiated against the petitioner. The Court directed that a copy of the order be communicated to the learned trial Court for information and disposed of all pending applications, if any.
Case Title: Manjit @ Mandeep Kaur v. State of Odisha & Anr.
Case No.: CRLMC No.852 of 2026
Date of Order: 09.04.2026
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