Domestic Violence Allegations Can’t Always Be Painted as Attempt to Murder: Meghalaya High Court Invokes Section 482 CrPC to Quash Matrimonial Assault Case Post-Settlement

“There’s a Growing Tendency to Label Domestic Fights as Section 307 IPC Offences” In a decision that underscores the nuanced application of criminal law in matrimonial disputes, the High Court of Meghalaya at Shillong on December 4, 2025, quashed proceedings in a pending sessions case involving serious charges including attempt to murder (Section 307 IPC), after the estranged couple reached a voluntary settlement.

Justice B. Bhattacharjee, deciding Crl. Petn. No. 66 of 2025, ruled that when allegations arise solely from a personal matrimonial conflict without premeditated criminal intent, and the parties genuinely settle their dispute, the inherent jurisdiction under Section 482 of the Code of Criminal Procedure can be invoked to prevent abuse of process and secure the ends of justice.

"No Public Element Involved – Case Entirely Personal in Nature Between Spouses"

The case arose from a complaint filed on October 31, 2023, by the wife (Respondent No.3), accusing her husband, the petitioner Shri Suresh Prasad Singh, of stabbing her with a knife, kicking her, and causing injuries to her fingers. An FIR was registered at Laban Police Station, and after investigation, a charge sheet under Sections 324, 326, and 307 IPC was filed and numbered as Sessions Case No. 20 of 2024.

However, during the pendency of the trial, the couple underwent mediation and voluntarily executed a compromise deed on August 11, 2025, expressing intent to reconcile and terminate all pending litigation. The wife agreed to support the quashing of the criminal case. Relying on this deed, the petitioner approached the High Court for quashing of the sessions case.

“A Slant of Section 307 IPC is Often Given to Domestic Quarrels” – Court Cautions Against Mechanical Invocation of Graver Charges

Referring to the Supreme Court’s observations in Naushey Ali v. State of U.P. (2025) 4 SCC 78, the Court noted that:

“Though it is a serious offence as the accused attempted to take the life of another, at the same time, the court cannot be oblivious to hard realities — that many times whenever there is a quarrel between the parties leading to physical commotion and injuries, there is a tendency to give it a slant of an offence under Section 307 IPC.”

Justice Bhattacharjee found this caution particularly applicable, observing:

“The materials on record do not show presence of any pre-mediated criminal intention on the part of the petitioner to cause harm... The quarrel led to a physical commotion, but not an act with murderous intent.”

“Court’s Inherent Powers Must Be Used to Foster Peace Where the Dispute Is Personal and Settlement Is Genuine”

While acknowledging that Section 307 IPC is non-compoundable, the Court clarified that settlements in cases of private and personal disputes—especially matrimonial—can be considered under Section 482 CrPC, provided the compromise is voluntary and without coercion. The Court relied on Gyan Singh v. State of Punjab (2013) 10 SCC 303, which laid down the parameters for quashing proceedings on the basis of compromise in non-compoundable cases.

Justice Bhattacharjee remarked: “Where the dispute arises out of matrimonial discord and parties voluntarily arrive at a compromise to promote harmony, the High Court can exercise discretion under Section 482 CrPC even in serious offences, if no public interest is at stake.”

He also noted that the compromise deed not only resolved the dispute but also included mutual commitments to maintain peace in the relationship.

“Judicial Discretion, Not Rigidity, Must Guide Application of Criminal Law in Family Disputes”

The Court carefully examined the settlement agreement, which included a clause obligating both parties to refrain from any future acts that may prejudice the other. Clause 6 of the compromise deed expressly stated that the wife would support the petition for quashing and cooperate with the legal process to end the case.

On this basis, the Court held: “Having regard to the fact that the dispute has been settled between the parties out of their own free will and aimed at boosting cordial and peaceful relations, this Court deems it fit to allow the petition.”

Sessions Case Quashed in the Interest of Justice

Holding that no public interest would be served by continuing the prosecution, the High Court quashed Sessions Case No. 20 of 2024, pending before the District and Sessions Judge, Shillong, and allowed the criminal petition.

The decision reaffirms the judiciary’s commitment to balancing the gravity of criminal charges with the practical realities of matrimonial disputes, especially when the complaint arises in the heat of personal conflict and the parties subsequently choose reconciliation.

Date of Decision: 4 December 2025