Supreme Court Quashes Rape and Assault FIRs in Rare Case of Mutual Settlement Post Dual Allegations

New Delhi, July 17, 2025

In a significant judgment, the Supreme Court of India has quashed two FIRs—including one under Section 376 of the Indian Penal Code—after finding that the allegations in the second FIR appeared to be reactionary and that both parties had amicably resolved their disputes. The Court invoked its inherent powers under Section 482 of the Code of Criminal Procedure, stating that continuing prosecution would serve no meaningful purpose and amount to abuse of the process of law.

The case involved Madhukar & Ors. and Prabhakar (Appellants) versus The State of Maharashtra & Anr. (Respondents), arising from two separate but closely linked criminal complaints registered in November 2023 at Mehunbare Police Station, Jalgaon.

The first FIR (Crime No. 302/2023) accused the appellants of assault and unlawful assembly allegedly due to a family dispute relating to divorce. The second FIR (Crime No. 304/2023), filed the very next day, alleged serious offences including rape, sexual harassment, and criminal intimidation against Prabhakar, the father of the complainant in the first case.

While the High Court had earlier refused to quash the proceedings on the ground that rape is a non-compoundable offence and settlement cannot override statutory gravity, the Supreme Court took a different view considering the peculiar sequence of events, the complainant’s categorical disinterest in prosecuting the matter, and the fact that she is now married and wishes to move on.

Justices Vikram Nath and Sanjay Kumar, in their judgment, observed, “Ordinarily, quashing of proceedings involving such offences on the ground of settlement is discouraged. However, the Court is not constrained by a rigid formula under Section 482 CrPC. The continuation of the trial would only prolong distress for all concerned, especially the complainant, and burden the Courts without likelihood of a productive outcome.”

The Court further noted that the complainant had submitted an affidavit supporting the settlement and confirming receipt of ₹5,00,000 towards marriage-related expenses, and had consistently maintained her unwillingness to pursue the charges.

Allowing the appeals, the Supreme Court set aside the Aurangabad Bench’s order dated March 7, 2025 and quashed both FIRs and all consequential proceedings, including Sessions Case No. 29 of 2024.