The Rajasthan High Court has quashed criminal proceedings in a case involving allegations under several provisions of the Indian Penal Code after noting the unusual facts placed before it. The Court found that the complainant and the accused had voluntarily married before the FIR was registered, later reunited after years of separation, and were now living together as husband and wife with the acceptance of both families.
Justice Baljinder Singh Sandhu observed that continuing the prosecution in these exceptional circumstances would not advance the cause of justice and would instead disturb the settled matrimonial life of the parties.
Background of the Case
The petition was filed by Pankaj Goyal seeking quashing of criminal proceedings arising out of FIR No. 202/2020 registered at Police Station Soorsagar, Jodhpur. The FIR invoked offences under Sections 376, 376(2)(n), 377, 384, 506 and 450 of the Indian Penal Code. The petitioner approached the High Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, stating that the dispute had been amicably resolved and that both parties were living together as husband and wife.
During the hearing, the complainant personally appeared before the Court. She stated that she had married the petitioner before the FIR was lodged. According to her, after the marriage both returned to their respective homes, but when her parents came to know of the marriage, the FIR was lodged under family pressure. She further stated that in December 2025 she reunited with the petitioner, following which both families accepted their relationship, and since December 25, 2025, they had been residing together as husband and wife.
The Public Prosecutor informed the Court that the trial had already reached an advanced stage, with most prosecution witnesses having been examined. However, it was not disputed that the parties were presently living together. Counsel appearing for the complainant also confirmed that the matter had been settled.
Court's Observations
The High Court noted that both parties were majors at the time of their marriage in 2020 and that their relationship had continued for more than six years despite the pending criminal proceedings. The Court observed that the material before it suggested that the criminal case had originated due to family pressure and that the couple had now consciously chosen to continue their married life together.
Referring to decisions of the Supreme Court, including Prashant Bhartiya v. State of Delhi, Madhukar v. State of Maharashtra and Mahesh Mukund Patel v. State of U.P., the Court reiterated that while allegations under Section 376 IPC are ordinarily serious and should not be quashed merely because of a settlement, the High Court's inherent powers may be exercised in exceptional cases where continuation of proceedings would serve no useful purpose.
“The relationship between the parties has survived the passage of almost six years... They have reunited and are presently living together as husband and wife,” the bench observed.
The Court further remarked,
“Continuation of the present criminal proceedings would neither subserve the cause of justice nor achieve the object of criminal law.”
Court's Decision
Allowing the petition, the Rajasthan High Court quashed the entire criminal proceedings in Sessions Case No. 14/2021, including all consequential proceedings arising out of FIR No. 202/2020.
The Court held that, considering the peculiar facts of the case and the unequivocal stand taken by the complainant, continuation of the prosecution would amount to an abuse of the judicial process.
All pending applications were also disposed of.
Case Details
Case Title: Pankaj Goyal v. State of Rajasthan & Anr.
Case Number: S.B. Criminal Miscellaneous (Petition) No. 4770/2026
Judge: Hon'ble Mr. Justice Baljinder Singh Sandhu
Decision Date: 08 July 2026
