ADVOCATEMMMOHAN: Dowry Prohibition Act, 1961 — Sections 3 & 4 — Conviction — Compromise during pendency of appeal — Power of High Court. Where the parties to a matrimonial dispute amicably settle their differences during the pendency of the criminal appeal and the victim voluntarily states that she has no objection to setting aside the conviction, the High Court, in the interest of preserving family harmony and welfare of the child, may record the compromise and set aside the conviction by applying the principles laid down in Gian Singh v. State of Punjab. (Paras 5 & 6).

Thursday, July 16, 2026

Dowry Prohibition Act, 1961 — Sections 3 & 4 — Conviction — Compromise during pendency of appeal — Power of High Court. Where the parties to a matrimonial dispute amicably settle their differences during the pendency of the criminal appeal and the victim voluntarily states that she has no objection to setting aside the conviction, the High Court, in the interest of preserving family harmony and welfare of the child, may record the compromise and set aside the conviction by applying the principles laid down in Gian Singh v. State of Punjab. (Paras 5 & 6).

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CHODAGIRI MAHINDRA KUMAR & OTHERS v. STATE OF ANDHRA PRADESH & ANOTHER

Criminal Appeal No.717 of 2024, decided on 16-07-2026 (A.P. High Court)

Case Facts

The appellants (Accused Nos.1 to 3) preferred a Criminal Appeal under Section 415 of the Bharatiya Nagarik Suraksha Sanhita, 2023, challenging the conviction and sentence imposed upon them for the offences punishable under Sections 3 and 4 of the Dowry Prohibition Act, 1961. During the pendency of the appeal, the accused and the de facto complainant (wife) personally appeared before the High Court, established their identity, and informed the Court that they had amicably settled the matrimonial dispute in the interest of their family and minor child. The victim expressed that she had no objection to setting aside the conviction. (Paras 1 to 4).

Holding

The High Court, taking note of the compromise entered into between the parties and relying upon the decision of the Supreme Court in Gian Singh v. State of Punjab, recorded the compromise, allowed the interlocutory applications, set aside the conviction and sentence imposed under Sections 3 and 4 of the Dowry Prohibition Act, cancelled the bail bonds, and directed refund of the fine amount, if any, in accordance with law. (Paras 5 to 7).

Legal Position

Dowry Prohibition Act, 1961 — Sections 3 & 4 — Conviction — Compromise during pendency of appeal — Power of High Court.

Where the parties to a matrimonial dispute amicably settle their differences during the pendency of the criminal appeal and the victim voluntarily states that she has no objection to setting aside the conviction, the High Court, in the interest of preserving family harmony and welfare of the child, may record the compromise and set aside the conviction by applying the principles laid down in Gian Singh v. State of Punjab. (Paras 5 & 6).

Criminal Appeal — Matrimonial offences — Compromise — Effect.

A genuine and voluntary settlement between the spouses, entered into without coercion and verified by their personal appearance before the Court, constitutes a valid ground for accepting the compromise and terminating the criminal proceedings arising out of matrimonial discord, where such course advances the ends of justice. (Paras 3 to 6).

Compromise — Consequential reliefs.

Upon acceptance of the compromise and setting aside the conviction, the bail bonds executed by the accused are liable to be cancelled and the fine amount, if already paid, is liable to be refunded in accordance with law. (Para 6).

Case Relied Upon

Gian Singh v. State of Punjab & Another, (2012) 10 SCC 303 / 2012 (9) Scale 257 — Compromise in matrimonial disputes and exercise of inherent powers to secure the ends of justice. (Para 5).

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