Justices Vikram Nath and Sanjay Kumar Allow Parties to Move On: Supreme Court Quashes FIRs After Woman Says She No Longer Supports Prosecution

Probably one of the most important decisions in this regard was made in July 14, 2025, by the Supreme Court of India, in the case of

Madhukar & Ors. v. The State of Maharashtra and Anr. and prabhakar v. The State of Maharashtra & Anr., had dealt with the much intricate matter of quashing criminal trials especially in cases of the nature of serious offenses that could not be compounded such as Section 376 of the Indian Penal Code (IPC). This case came up as a judgment of Criminal Appeal No(s). 1502 of 2025 ( arising out of SLP(Crl.) No.(s) 7212/2025 and 1502/2025 (arising out of SLP(Crl). [(No. 7495 of 2025)], shows how pragmatic the Court can be in exercising its powers of the inherent nature under Section 482 of the code of criminal procedure, 1973 (CrPC) to advance the end of justice, even in extraordinary situations.

Case background: FIRs intertwined and Amicable solution of the same:

These appeals take their origin in two First Information Reports (FIRs) filed at Mehunbare Police Station, District Jalgaon, Maharashtra. The original FIR, Crime No. 302 of 2023 dated 20.11.2023 was filed against Madhukar and others, which contained the violent offenses of different sections of the IPC including Sec. 324 (voluntarily causes hurt by dangerous means or weapons), Sec. 141 (unlawful assembly), Sec. 143 (being a member of an unlawful assembly), Sec. 147 (punishment of rioting), Sec. 149 (every member of unlawful The origin of this FIR owes to an alleged Assembly of Persons Unlawfully Armed and an assault on the complainant and her family on November 19, 2023, presumably over Prabhakar (appellant in the second appeal) having appeared to play some role revolving around one of the divorce cases of the first appellant.

The second FIR Crime No. 304 of 2023 was on the next day that is, November 21, 2023 against Prabhakar on Sections 376 (rape), 354-A (sexual harassment and punishment for sexual harassment), 354-D (stalking), 509 (word, gesture or act intended to insult the modesty of a woman), 506 (criminal intimidation) of the IPC. This FIR alleged serious offences of rapes, video-tapping and tampering with the matrimonial affiliations of the complainant.

A major twist also came when a complainant in the second FIR submitted an affidavit before the High Court in March 2024. In this affidavit, she was categorical that this is not what she wanted in prosecuting this case, that, she did not object to the bail being granted to the accused. In addition, she also confirmed that, the issue was enveloped in a friendly fashion and that she had been given Rs. 5,00,000/- as marriage related expenses.

The position of the High Court and intervention of the Supreme Court

In pursuant to this friendly settlement, the appellants moved an application in the High Court of Judicature at Bombay, Aurangabad Bench, under Criminal Applications No. 2561 and 2185 of 2024 under Section 482 CrPC to quash both the FIRs. A common order was however passed by the High Court on March 7, 2025 which dismissed these petitions. High Court observed that, an offence under Section 376 IPC is a grievous and one which is not compoundable; just because there is a settlement or compensation, the offence under that section under IPC cannot be quashed. This Court held that such compromise will not accord the foundation of quashing the proceedings in such cases. the appellants did not like this ruling and made an appeal to the Supreme Court.

Fundamental Issues and the Supreme Court’s Reasoning

The core issue before the Supreme Court was whether criminal proceedings, particularly those involving a serious non-compoundable offense like rape, could be quashed under Section 482 CrPC based on an amicable settlement between the parties.

At the very onset of this case, the Supreme Court conceded that by reason of its Section 376 IPC being of a “grave and heinous nature”, the offence “is undeniably of a very deeply serious nature” and that the norm is normally that, the proceedings relating to the offence so described are settled, then the quashing of proceedings should be discouraged and should never be done easily. Nonetheless, the Court made it clear that its discretion to “do complete justice” under Section 482 CrPC is not, however, under strict technical rules, but the power must be used after considering the facts of a particular case.

The Court considered the facts and their presentation produced an aberrant scenario. It noted that the second FIR, containing serious charges including Section 376 IPC, was filed immediately after the first FIR lodged by the opposing side. This sequence of events, in the Court’s view, lent “a certain context to the allegations and suggests that the second FIR may have been a reactionary step”.

What is more important is that the Supreme Court accorded great importance to the fact that the complainant was fully unenthusiastic about taking the case forward in the second FIR. The Court observed her to have always stated, even in an affidavit filed on record that she is not in support of the prosecution and that she wishes the case to be over. She had also pointed out that she is currently married and is settled in her personal life and carrying on with the criminal proceedings would only disrupt her life and conscience. Moreover, the conflict between the parties was solved peacefully, and each of them understood each other.

The Court reasoned that in such circumstances, the continuation of the trial would not serve any meaningful purpose. It would only prolong distress for all concerned, especially the complainant, and burden the courts without the likelihood of a productive outcome.

The Verdict: Justice with a Whole Picture

given the peculiar facts and circumstances, the categorical position of the complainant and the kind of settlement entered into, the Supreme Court held that no useful purpose would be served by persisting with the criminal proceedings and that by now it would only constitute an abuse of process of law.

The Supreme Court, therefore, set aside the impugned order of the High Court dated and granted leave to appeal. FIR No. 302 of 2023, as well as FIR No.304 of 2023 and all process carried forward thereof including Sessions Case No. 29 of 2024 was quashed.

Such an opinion by Justices Vikram Nath and Sanjay Kumar highlights the fact that the Supreme Court is open to showing such a holistic and practical vision on justice even in cases that are sensitive to it where, based on the overwhelming facts and circumstances, it is clear that carrying on with criminal proceedings would be nothing but an exercise in futility and would be against the interest of the parties concerned, and especially the victim. It confirms once again that the discretionary powers bestowed upon the High Court and the Supreme Court under Section 482 CrPC is so wide enough to bar abuse of process and achieve the ends of justice in meritorious cases although the crimes in question may be non-compoundable in nature.