Mange Ram vs State of Madhya Pradesh 2025 INSC 962 - S.482 CrPC - Quashing Power - Matrimonial Cases

Code of Criminal Procedure 1973 - Section 482- while exercising power under Section 482 CrPC to quash the criminal proceedings in respect of non-compoundable offences, which are private in nature and do not have a serious impact on society, on the ground that there is a settlement/compromise between the victim and the offender, it is necessary to consider the antecedents of the accused; the conduct of the accused, namely, whether the accused was absconding and why he was absconding, how he had managed with the complainant to enter into a compromise, etc. (Para 29) Matrimonial Matters - Where the matrimonial relationship has come to an end by way of divorce, and the parties have since settled in their respective lives, criminal prosecution emanating from that past relationship ought not to be permitted to linger as a means of harassment. (Para 26) Once the marital relationship has ended in divorce and the parties have moved on with their lives, the continuation of criminal proceedings against family members, especially in the absence of specific and proximate allegations, serves no legitimate purpose. It only prolongs bitterness and burdens the criminal justice system with disputes that are no longer live. The law must be applied in a manner that balances the need to address genuine grievances with the equally important duty to prevent its misuse. In appropriate cases, the power to quash such proceedings is essential to uphold fairness and bring about a quietus to personal disputes that have run their course. (Para 33)