Citing Amicable Settlement and Complainant's Unambiguous Stance, Supreme Court Quashes and FIR in Section 376 FIR.

Supreme Court Quashes Criminal Proceedings in case of Madhukar & Ors Vs The State Of Maharashtra & Anr and in case of Prabhakar & Ors Vs The State Of Maharashtra & Anr., wherein it set aside a High Court order and quashed two First Information Reports (FIRs), including charges under Section 376 of the Indian Penal Code (IPC), following an amicable settlement between the parties.

The Apex Court underscores that the High Court's exercise of its power under Section 482 of the Code of Criminal Procedure (CrPC) in unique circumstances, even in cases involving grave and non-compoundable offences and also highlights the application of Section 482 CrPC to secure the ends of justice in peculiar circumstances despite the grave nature of the offence.

Case Background: The genesis of the appeals lies in two separate but related FIRs registered at Mehunbare Police Station, District Jalgao The first FIR was registered under sections 324, 141, 143, 147, 149, 452, 323, 504, and 506 IPC for the alleged involment of the appellant in forming unlawful assembly and for assaulting the complainant and her family including her father, due to their alleged role in one of the appellant's divorces.

A second FIR, Crime No. 304 of 2023, was subsequently registered the very next day, at the same police station. This second FIR contained grave allegations, including sexual assault and criminal intimidation, under Sections 376, 354-A, 354-D, 509, and 506 IPC. It was alleged that Prabhakar had sexually exploited the complainant over time, recorded videos of the acts, and interfered with her subsequent matrimonial alliances. However, after a few months, the complainant filed an affidavit before the High Court, expressing her desire not to pursue the prosecution in the second FIR. She also stated that she had no objection to the grant of bail to the accused and affirmed that the matter had been amicably resolved, having received Rs. 5,00,000/- towards marriage-related expenses.

Based on this development, the appellants moved the High Court under Section 482 CrPC seeking to quash both FIRs. The High Court of Judicature at Bombay, Aurangabad Bench, by a common order dated March 7, 2025, rejected both applications. The High Court's rationale was that an offence under Section 376 IPC is of a serious and non-compoundable nature, and thus, could not be quashed merely on the basis of a settlement or monetary compensation. Aggrieved by this decision, the appellants approached the Supreme Court.

The Supreme Court, while acknowledging the grave nature of an offence under Section 376 IPC, made following observations:

Amicable Resolution and Complainant's Stance: The Apex Court noted that both parties had categorically taken the stand before the Supreme Court that they had amicably resolved their disputes and desired to move on with their lives. Crucially, the complainant in the second FIR, who was now married and residing with her husband, "has expressed that continuation of the prosecution would cause further disruption in her personal life and that she has no wish to support the charges or pursue the matter any further". Her stand was described as "neither tentative nor ambiguous", consistently maintained, including through an affidavit on record.

Contextual Filing of FIRs: The Supreme Court found the "unusual situation where the FIR invoking serious charges, including Section 376 IPC, was filed immediately following an earlier FIR lodged by the opposing side". This sequence of events was observed to lend "a certain context to the allegations and suggests that the second FIR may have been a reactionary step".

Pragmatic Approach to Justice: While recognizing that quashing proceedings for grave offences like Section 376 IPC on settlement grounds is ordinarily discouraged and "should not be permitted lightly", the Apex Court emphasized that "the power of the Court under Section 482 CrPC to secure the ends of justice is not constrained by a rigid formula and must be exercised with reference to the facts of each case".

Futility of Continued Prosecution: The Apex Court opined that in these specific circumstances, where the parties had resolved their differences and the complainant unequivocally wished to end the matter, "the continuation of the trial would not serve any meaningful purpose". It further stated that it "would only prolong distress for all concerned, especially the complainant, and burden the Courts without the likelihood of a productive outcome".

Abuse of Process: Considering the "peculiar facts and circumstances" and the complainant's categorical stand and settlement, the Supreme Court concluded that "the continuation of the criminal proceedings would serve no useful purpose and would only amount to abuse of process". Thus, it allowed the appeals, setting aside the High Court's order and quashing FIRs along with all proceedings arising therefrom.

Coram: Justice Vikram Nath and Justice Sanjay Kumar.