No Straightjacket Formula for S.482 CrPC in Heinous Offences, Rules SC

In its judgment dated July 14, 2025, the Supreme Court acknowledged that the offence of rape under Section 376 IPC is of a grave and heinous nature, and ordinarily, proceedings involving such charges should not be quashed in a routine manner, merely on the basis of a settlement, however, it clarified that the High Court’s power under Section 482 CrPC to secure the ends of justice is not governed by any rigid formula and may be exercised even in such cases - though sparingly and with great caution - depending on the facts and circumstances of each matter.

A bench of Justices Vikram Nath and Sanjay Kumar allowed separate appeals filed by Madhukar and others and Prabhakar against the Bombay High Court's judgment of March 7, 2025 which dismissed their petitions filed under Section 482 of the Code of Criminal Procedure, seeking quashing of criminal proceedings initiated against them.

The court noted both parties have categorically taken the stand that they have resolved their disputes amicably and are desirous of moving on with their lives.

"We are confronted with an unusual situation where the FIR invoking serious charges, including Section 376 IPC, was filed immediately following an earlier FIR lodged by the opposing side. This sequence of events lends a certain context to the allegations and suggests that the second FIR may have been a reactionary step," the bench said.

Brief Background

Two FIRs were lodged in the matter. In the first FIR, it was alleged on November 19, 2023, the appellants formed an unlawful assembly and assaulted the complainant and her family members, including her father Prabhakar (appellant in one special leave petition ), allegedly due to his role in causing the divorce of one of the appellants.

The second FIR, filed the following day, contained grave allegations against Prabhakar, including sexual assault and criminal intimidation. It was alleged that he had sexually exploited the complainant over the time, recorded videos of the act, and interfered with her subsequent matrimonial alliances.

In March 2024, the complainant in the second FIR filed an affidavit before the High Court expressing her desire not to pursue the prosecution and stating that she had no objection to grant of bail to the accused. She further affirmed that the matter had been amicably resolved, and she had received Rs 5,00,000 towards marriage-related expenses.

The appellants approached the High Court, which rejected both applications, holding that an offence under Section 376 IPC being of a serious and non-compoundable nature, could not be quashed merely on the basis of a settlement or monetary compensation. The court concluded that the compromise could not form the basis for quashing proceedings in such cases.

Having noted the facts of the matter, the bench said, 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 bench said.

The parties have also amicably resolved their differences and arrived at a mutual understanding, the court added.

"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," the bench said, holding the continuation of the proceedings would amount to abuse of process.

Case Title: Madhukar & Ors Vs The State of Maharashtra & Anr.