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Bombay High Court

MANISH SHASHIKANT PATIL AND ANOTHERversusTHE STATE OF MAHARASHTRA AND ANOTHER

Disposal
APPLICATION ALLOWED

Holding

The court held that there is no purpose in continuing the prosecution and quashed the FIR.

Summary

Manish Patil and his sister‑in‑law Shweta Patil applied to quash FIR No.0159 of 2023 filed under IPC sections 498‑A, 323, 504, 506 r/w 34. The informant, respondent No.2, appeared in court and submitted an affidavit stating that the parties have amicably settled their matrimonial dispute and have filed a mutual‑consent divorce. The court noted the nature of the allegations but, relying on the Supreme Court’s decision in Narindar Singh v. State of Punjab (2014) 6 SCC 464, held that continuing prosecution would serve no purpose. Consequently, the criminal application was allowed and the FIR was quashed. The matter was disposed of.

Issues considered

  • Whether an FIR for offences under sections 498‑A, 323, 504, 506 r/w 34 can be quashed when the parties have reached an amicable settlement of their matrimonial dispute.

Legislation cited

Subjects

  • criminal procedure
  • quashment of FIR
  • section 498-A
  • amicable settlement
  • mutual consent divorce
  • maternity dispute

Judgment

2026:BHC-AUG:2089-DB


                                                 1                     cran 4259.25.odt

                          IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                                     BENCH AT AURANGABAD

                              950 CRIMINAL APPLICATION NO. 4259 OF 2025

                                  Manish Shashikant Patil And Another
                                                VERSUS
                                 The State Of Maharashtra And Another
                                                   ...
                         Advocate for Applicants : Mr. V.S. Wakale
                         APP for Respondents: Mr. V.M. Lomte
                         Mr. S.G. Ghongade advocate for respondent no.2.
                                                   ...

                                        CORAM : S. G. CHAPALGAONKAR, J.
                                       Dated      : January 17, 2026

                   PER COURT :-

                   1.    The     applicant   no.1-Manish   s/o   Shashikant      Patil

                   (Husband) and no.2-Shweta Shashikant Patil (sister-in-law)

                   seek quashment of the FIR bearing Crime No.0159 of 2023

                   registered with Deopur Police Station, Dhule for the offence

                   punishable under sections 498-A, 323, 504, 506 r/w 34 of the

                   Indian Penal Code and charge-sheet filed against them.


                   2.    Respondent No.2/informant is personally present before

                   the Court and submits that she has amicably settled the

                   dispute.    It is submitted that divorce proceeding by mutual

                   consent is already filed by parties. The applicant and

                   respondent no.2 are residing separately.      Learned advocate
                              2                     cran 4259.25.odt

appearing for respondent no.2 files on record affidavit of

respondent no.2 containing aforesaid facts.


3.      Considering nature of allegations and fact that parties

have arrived at amicable settlement of matrimonial dispute

and taking into account law laid down by the Supreme Court

in case of Narindar Singh and others Vs. State of Punjab and

another reported in (2014) 6 SCC 464, no purpose would be

served by continuing the prosecution.          Hence, Criminal

Application is allowed in terms of prayer clause “A” and

disposed off.

                                  ( S. G. CHAPALGAONKAR, J. )
                                  …



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