Addressing the intricacies surrounding criminal proceedings related to rape offenses, the Supreme Court bench of Justice Vikram Nath and Justice Sanjay Kumar, affirmed that in exceptional situations, such cases could be quashed based on settlements, contingent upon the specifics surrounding each case.

The Court remarked “At the outset, we recognise that the offence under Section 376 IPC is undoubtedly of a grave and heinous nature. Ordinarily, quashing of proceedings involving such offences on the ground of settlement between the parties is discouraged and should not be permitted lightly. However, the power of the Court under Section 482 Cr.P.C. to secure the ends of justice is not constrained by a rigid formula and must be exercised with reference to the facts of each case.”

The bench was reviewing an appeal against a decision made by the Aurangabad Bench of the Bombay High Court. The High Court had previously declined to quash the rape case against the defendants even after the prosecutrix expressed her desire to drop the charges, asserting that the misunderstandings between her and the accused had been amicably settled.

In light of the situation, the bench concluded that the second First Information Report (FIR) filed by the prosecutrix appeared to be a reaction to the initial FIR, holding no substantial purpose in continuing the case. Consequently, they decided to quash the pending proceedings.

The court elaborated, saying, “More importantly, the complainant in the second FIR has unequivocally expressed her desire not to pursue the case. She has submitted that she is now married, settled in her personal life, and continuing with the criminal proceedings would only disturb her peace and stability. Her stand is neither tentative nor ambiguous; she has consistently maintained, including through an affidavit on record, that she does not support the prosecution and wants the matter to end. The parties have also amicably resolved their differences and arrived at a mutual understanding. In these 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.”

In delivering their judgment, the bench emphasized the need to critically understand the unique facts and circumstances of each case.

“Therefore, having considered the peculiar facts and circumstances of this case, and taking into account the categorical stand taken by the complainant and the nature of the settlement, we are of the opinion that the continuation of the criminal proceedings would serve no useful purpose and would only amount to abuse of process.” they stated.

Case Detail : Madhukar & Ors. Versus The State of Maharashtra & Anr.

Advocate For Petitioner’s : Ms. Bina Madhavan, Adv. Mr. S.. Udaya Kumar Sagar, Adv. Mr. S. Tridev Sagar, Adv. M/S. Lawyer S Knit & Co, AOR Ms. Praseena Elizabeth Joseph, AOR Ms. Shreyasi Kunwar,