Can Rape FIR Be Quashed On Settlement? Supreme Court Explains Limits

The Supreme Court of India has said that, as a general rule, heinous offences should not be quashed merely because the parties have reached a settlement, since such crimes affect society at large. However, it clarified that in cases where two individuals were in a relationship but could not marry due to family differences, proving allegations of rape may become difficult.

A Bench of Justice Manoj Misra and Justice Manmohan allowed an appeal filed by one Shivaji Gangadhar Ingale and others, and quashed a 2017 FIR registered under Sections 376 [corresponding to Sections 64 of the Bharatiya Nyaya Sanhita (BNS)], 377 (omitted from the BNS), 420 [Section 318 (4), BNS], 384 [Section 308 (2), BNS], 204 (Section 24, BNS), 504 (Section 352, BNS), 506 [Section 351 (2)/(3), BNS], 34 (Section 3(5), BNS) of the Indian Penal Code (IPC), along with Section 66(e) of the Information Technology Act and Section 4 of the POCSO Act.

According to the allegations, the first instance of sexual assault occurred in 2009 when the prosecutrix was a minor, and the relationship continued till 2012. During this period, a mock marriage ceremony was also performed in 2010. It was further alleged that the parents of the main accused were demanding dowry, which prevented the formal solemnisation of the marriage.

Subsequently, a settlement was reached between the parties. It was stated that the FIR had been lodged due to a misunderstanding and pressure from the prosecutrix’s parents. Based on this compromise, a petition was filed before the high court seeking quashing of the proceedings.

However, by its order dated November 21, 2025, the high court refused to quash the case, observing that the allegations involved heinous offences which cannot ordinarily be set aside on the basis of a compromise.

Before the Supreme Court, counsel for the appellants argued that the prosecutrix herself had admitted in an affidavit that the relationship was consensual, and that the FIR was filed out of anger when the relationship could not culminate in marriage due to family disputes.

Counsel for the prosecutrix also submitted that she is now married and settled, and continuing the case would adversely affect her mental well-being and disturb her married life.

After hearing the parties, Court noted that the material on record did not suggest a case of violent sexual assault, and that the FIR related to incidents that had taken place 7–8 years earlier. It also noted that the prosecutrix was an adult at the time of lodging the FIR.

The Bench observed that the prosecutrix’s statement before the high court, that the FIR was filed as a reaction to the failure of the relationship to result in marriage, appeared to carry some truth and could not be ignored.

Court further said that the allegation of sexual exploitation when the prosecutrix was a minor would be difficult to prove, particularly since the POCSO Act was not in force at the relevant time, and therefore its presumptions would not apply.

Taking into account these circumstances, including the compromise and the low likelihood of conviction, Court held that continuing the criminal proceedings would not serve the ends of justice.

Accordingly, Court allowed the appeal, set aside the high court’s order, and quashed the criminal proceedings.

Case Title: Shivaji Gangadhar Ingale & Ors Vs State of Maharashtra & Anr

Bench: Justices Manoj Misra and Manmohan

Date of Judgment: February 11, 2026