Facts and Background
The case originated from matrimonial disputes between husband and his wife. Multiple criminal proceedings and related cases were pending between the parties, stemming from allegations typically associated with matrimonial discord including proceedings under Section 498A IPC and other related provisions, as well as other collateral cases. The appellants filed a petition under Section 482 CrPC before the Allahabad High Court seeking to quash the criminal proceedings. The High Court rejected the application, leading to the appeal before the Supreme Court.
Observations of Supreme Court
The Supreme Court allowed the appeal and exercised its extraordinary plenary powers under Article 142 of the Constitution of India to do complete justice. The marriage between the parties was dissolved on the ground of irretrievable breakdown of marriage. All pending criminal proceedings and collateral cases between the parties were quashed. The Court emphasized that continuing the litigation would serve no purpose when the parties had amicably settled and wished to end the disputes. This promotes closure and prevents abuse of the process of law. The High Court's rejection of the Section 482 petition was set aside.
Conclusion
This judgment reaffirms the Supreme Court's approach in recent years to invoke Article 142 in matrimonial disputes where:
The marriage is irretrievably broken, parties have arrived at a genuine settlement, and continuation of proceedings would cause unnecessary hardship. It highlights the Court's priority to secure "complete justice" in family-related matters by dissolving marriages and closing associated criminal cases when mutual consent and settlement are evident.
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