Supreme Court invokes Article 142 to quash criminal proceedings and dissolve marriage after verified matrimonial settlement

The Supreme Court of India has exercised its powers under Article 142 of the Constitution to quash criminal proceedings arising out of a matrimonial dispute and to dissolve the marriage between the parties by mutual consent. The Court held that where parties to a matrimonial dispute have voluntarily arrived at a comprehensive settlement and have placed its terms before the Court, it may grant complete relief to bring finality to the proceedings covered by the settlement.

Allowing the criminal appeal, the Court set aside the refusal of the Allahabad High Court to quash the proceedings under Section 482 of the Criminal Procedure Code and recorded the settlement terms agreed between the husband and wife, including payment of a lump-sum amount and closure of the proceedings specifically listed in the joint application.

Case Background

The appeal arose from a matrimonial dispute between the third appellant (husband) and the second respondent (wife), which led to registration of Criminal Case No. IX of 2024 arising out of Case Crime No. 177 of 2023 at Mahila Thana, District Mathura. The criminal case was pending before the Court of the Civil Judge (Junior Division) / Judicial Magistrate, Mathura.

In addition to the criminal proceedings, both sides had instituted multiple cases against each other and their respective family members before different courts and authorities. The appellants sought quashing of the criminal proceedings by filing an application under Section 482 of the Criminal Procedure Code before the Allahabad High Court.

What The Lower Authorities Held

The Allahabad High Court rejected the application filed under Section 482 of the Criminal Procedure Code. As a result of this rejection, the criminal proceedings arising out of the matrimonial dispute continued to remain pending before the trial court.

Aggrieved by the refusal of the High Court to exercise its inherent powers to quash the proceedings, the appellants approached the Supreme Court by way of a special leave petition, which was subsequently converted into a criminal appeal.

The Court’s Reasoning

The Supreme Court examined whether it should exercise its constitutional powers to grant relief in light of the settlement arrived at between the parties. The Court recorded that when the matter was taken up earlier, the husband and wife had informed the Court that the dispute had been settled and that certain issues remained to be finalised before full compliance could be reported.

When the matter was taken up subsequently, the husband and wife were personally present before the Court. They informed the Court that the settlement had been finalised and that a joint application under Article 142 of the Constitution had been filed seeking dissolution of the marriage.

Verification of settlement

The Court took note of the joint application filed by the parties and extracted the relevant portions of the settlement. It recorded that the husband and wife had agreed to go their independent ways on a final settlement amount of Rs.30,00,000 to be paid by the husband to the wife.

The Court verified that a demand draft of Rs.15,00,000 dated 12 December 2025 had been prepared in favour of the wife and that another demand draft of Rs.15,00,000, which had earlier been returned, had been revalidated. The Court recorded that the demand drafts had been handed over for encashment.

Proceedings covered by the settlement

The Court examined the tabulated lists placed on record showing various cases instituted by the parties against each other before criminal courts, family courts, civil courts, the High Court, and administrative authorities. These lists formed part of the joint application filed before the Court.

The Court recorded the undertaking of the parties that the cases listed in the tabulated statements would not be proceeded with and that appropriate steps had already been taken or would be taken for their closure upon production of a certified copy of the Court’s order before the concerned courts and authorities.

The Court also recorded the undertaking of the parties to remove photographs and videos relating to each other and their family members from social media platforms and to refrain from uploading any such content in the future.

Statutory Interpretation

The Supreme Court clarified that the relief granted in the present case flowed from Article 142 of the Constitution of India. Article 142 empowers the Supreme Court to pass such decree or make such order as is necessary for doing complete justice in any cause or matter pending before it.

The Court distinguished this constitutional power from the inherent jurisdiction of the High Court under Section 482 of the Criminal Procedure Code. While Section 482 operates within statutory limits, Article 142 confers broader constitutional authority on the Supreme Court to grant appropriate relief where the facts and circumstances so warrant.

Constitutional / Policy Context

The Supreme Court expressly grounded its intervention in Article 142 of the Constitution of India. The provision empowers the Court to pass such decree or make such order as is necessary for doing complete justice in any cause or matter pending before it. In the present case, the Court made it clear that the relief granted could not have been secured through ordinary statutory mechanisms alone.

The Court contrasted its constitutional authority with the limited scope of the High Court’s inherent jurisdiction under Section 482 of the Criminal Procedure Code. While the High Court had declined to quash the criminal proceedings, the Supreme Court clarified that such refusal did not restrict its own power to grant appropriate relief under Article 142 once the parties had jointly approached it with a verified settlement.

The exercise of power was thus not based on any abstract policy consideration but on the concrete facts placed before the Court, including the voluntary settlement, personal presence of the parties, and compliance with the agreed terms. The Court confined its directions strictly to the proceedings and disputes covered by the settlement recorded in the joint application.

Scope and Limits of the Relief Granted

The Supreme Court was careful in delineating the scope of the relief it granted. The quashing of proceedings was limited to the criminal case and other proceedings specifically mentioned in the tabulated lists forming part of the joint application filed before the Court.

The Court did not issue any blanket declaration extinguishing all possible disputes between the parties. Instead, it relied on the undertakings furnished by the parties that they would not pursue the cases listed and that appropriate steps would be taken for closure of those proceedings before the concerned courts and authorities.

Similarly, the dissolution of marriage was granted by mutual consent under Article 142 on the basis of the joint request made by the parties. The Court did not adjudicate any contested matrimonial issue but recorded the agreed position of the parties seeking dissolution of their marriage.

Effect of Undertakings Recorded by the Court

A key feature of the order is the emphasis placed on undertakings furnished by both parties. The Supreme Court treated these undertakings as binding and integral to the relief granted. The undertakings covered withdrawal or non-prosecution of the cases listed in the settlement and compliance with ancillary terms agreed between the parties.

The Court also recorded the undertaking of the parties to remove photographs and videos relating to each other and their respective family members from social media platforms and not to upload such material in the future. This undertaking was accepted by the Court as part of the settlement framework.

By recording these undertakings in its order, the Court ensured that the settlement was not merely a private agreement but one carrying judicial sanction, enforceable through the authority of the Court.

Why This Judgment Matters

This judgment reaffirms the Supreme Court’s role in granting complete relief under Article 142 where statutory remedies are insufficient to bring finality to a dispute. It illustrates how the Court may act upon a verified settlement to resolve criminal proceedings arising from matrimonial discord.

The decision also clarifies that refusal by a High Court to exercise powers under Section 482 of the Criminal Procedure Code does not foreclose the Supreme Court’s constitutional authority to grant relief in appropriate cases.

For litigants, the judgment demonstrates the importance of placing a clear, comprehensive, and voluntary settlement on record when seeking relief under Article 142.

Final Outcome

The Supreme Court allowed the criminal appeal and set aside the order passed by the Allahabad High Court rejecting the application under Section 482 of the Criminal Procedure Code.

In exercise of its powers under Article 142 of the Constitution, the Court quashed the criminal proceedings arising out of Case Crime No. 177 of 2023 pending before the competent court at Mathura and directed closure of the proceedings listed in the settlement placed before it.

The Court dissolved the marriage between the husband and wife by mutual consent and recorded the payment of Rs.30,00,000 as full and final settlement in terms of the joint application. The undertakings furnished by the parties were accepted and made binding.

Case Details

• Case Title: Baburam Gautam and Others v. State of Uttar Pradesh and Another
• Citation: 2025 INSC 1493
• Court & Bench: Supreme Court of India; K. VINOD CHANDRAN J. and AHSANUDDIN AMANULLAH J.
• Date of Judgment: 18 December 2025