ANJUM ARA BEGUM & ORS. v. THE STATE (NCT OF DELHI) & ANR.
Transfer Petition (Criminal) No. 317/2025 (@ Diary No. 16766/2025)
Supreme Court of India
Sanjay Kumar and K. Vinod Chandran, JJ.
Order dated: 29 April 2026
HEADNOTES
1. Matrimonial dispute — Settlement through Supreme Court Mediation Centre — Settlement acted upon — Continuing multiple proceedings would serve no useful purpose — Proceedings quashed/disposed of in terms of settlement.
[Order] — During pendency of the transfer petition, the parties were referred to the Supreme Court Mediation Centre and successfully settled their differences. The terms were reduced into a Settlement Agreement dated 24.02.2026. In view of the settlement, the Court held that no purpose would be served in keeping alive the various proceedings initiated by the parties against each other and accordingly quashed/disposed of the proceedings specified in the settlement.
2. Matrimonial dispute — Settlement — Payment of ₹31 lakhs to wife — Demand draft handed over in Court — Settlement acted upon.
[Order] — In terms of the Settlement Agreement, the husband handed over a demand draft dated 07.02.2026 for ₹31,00,000/- to the respondent-wife, who was personally present before the Court.
3. Criminal proceedings — Matrimonial offences — Settlement between husband and wife — Supreme Court exercising jurisdiction to bring proceedings to an end.
[Order] — In view of the parties having amicably settled their disputes, the Court ordered that FIR No. 622/2020 under Sections 498-A, 406 and 34 IPC and Section 4 of the Muslim Women (Protection of Rights on Marriage) Act, 2019, together with all consequential proceedings including C.R. Case No. 7306/2024, stand quashed/disposed of in terms of the settlement.
4. Criminal proceedings instituted by husband against wife and her family — Settlement — Proceedings quashed/disposed of.
[Order] — FIR No. 606/2024 dated 06.12.2024, registered at P.S. Arariya, District Arariya, Bihar, under the provisions of the Bharatiya Nyaya Sanhita, 2023, and all consequential proceedings were ordered to stand quashed/disposed of in view of the settlement.
5. Civil proceedings — Matrimonial dispute — Settlement — Pending civil proceedings brought to an end.
[Order] — Civil Suit No. CS/14/2025 and Misc. DJ/54/2025, pending before Family Court No.2, District East, Karkardooma Courts, Delhi, were ordered to stand disposed of in terms of the settlement.
6. Departmental proceedings — Complaint by spouse — Matrimonial settlement — Proceedings discontinued.
[Order] — Departmental proceedings initiated against the husband on the complaint of the wife before North Bihar Power Distribution Company Ltd. were ordered to stand disposed of in view of the settlement between the parties.
7. Writ proceedings — Matrimonial dispute — Settlement — Proceedings rendered unnecessary.
[Order] — Writ Petition No. 1263/2021, Minhaz Ahmad v. Govt. of NCT, pending before the High Court of Delhi, was also ordered to stand disposed of in terms of the settlement.
8. Divorce — Marriage irretrievably broken down — Parties living separately since 2016 — Article 142 Constitution of India — Supreme Court empowered to dissolve marriage by decree of divorce.
[Order] — Since the parties were no longer desirous of continuing their marital relationship and had been living separately since 2016, the Supreme Court considered it appropriate to exercise its jurisdiction under Article 142 of the Constitution and dissolved the marriage by granting a decree of divorce.
9. Article 142 — Matrimonial settlement — Complete resolution of disputes — Power to do complete justice.
[Order] — Where matrimonial disputes have been comprehensively settled and the parties have decided not to continue the marital relationship, the Supreme Court may exercise its jurisdiction under Article 142 to give complete effect to the settlement, including dissolution of marriage and termination of connected proceedings.
10. Transfer Petition — Settlement — Disposal in terms of Settlement Agreement.
[Order] — I.A. No.108198/2026 seeking appropriate directions in terms of the settlement was allowed and the Transfer Petition was disposed of in the terms recorded by the Court.
CASE FACTS
The marriage between Minhaz Ahmed (petitioner No.3) and Ruana Rahman (respondent No.2) took place on 24.07.2016. The parties separated shortly thereafter and had been living separately since 2016. Petitioner Nos.1 and 2 were the parents of petitioner No.3.
Various proceedings had been instituted by the parties against each other arising out of their matrimonial dispute.
During the pendency of the Transfer Petition, the Supreme Court referred the parties to the Supreme Court Mediation Centre. The parties successfully settled their differences with the assistance of the learned Mediator.
The settlement was reduced into writing in a Settlement Agreement dated 24.02.2026.
Pursuant to the settlement, the parties filed I.A. No.108198/2026 seeking appropriate directions.
Under the settlement, the husband handed over to the wife, who was present personally in Court, a demand draft for ₹31,00,000/- dated 07.02.2026 drawn on State Bank of India, New Delhi Main Branch.
The parties also agreed that the various criminal, civil, departmental and writ proceedings arising out of their disputes should not be continued.
PROCEEDINGS ORDERED TO BE QUASHED / DISPOSED OF
(a) Wife's criminal case
FIR No. 622/2020, P.S. Laxmi Nagar, Delhi, under:
- Sections 498-A, 406 and 34 IPC; and
- Section 4 of the Muslim Women (Protection of Rights on Marriage) Act, 2019,
together with consequential proceedings including C.R. Case No. 7306/2024, pending before JMFC, Mahila Court, East Karkardooma, Delhi.
(b) Husband's criminal case
FIR No. 606/2024 dated 06.12.2024, P.S. Arariya, District Arariya, Bihar, registered under Sections 126(2), 115(2), 308(3), 74, 303(2), 352, 351(2) and 3(5) BNS, 2023, and consequential proceedings.
(c) Civil proceedings
Civil Suit No. CS/14/2025 and Misc. DJ/54/2025, pending before Family Court No.2, District East, Karkardooma Courts, Delhi.
(d) Departmental proceedings
Departmental proceedings against the husband initiated on the complaint of the wife by North Bihar Power Distribution Company Ltd., vide Resolution No.205 dated 08.04.2022.
(e) Writ proceedings
W.P. No.1263/2021, Minhaz Ahmad v. Govt. of NCT, pending before the Delhi High Court.
LAW
1. Settlement of matrimonial disputes
The Supreme Court recognised that the parties had voluntarily and successfully settled their differences through mediation. Once the settlement comprehensively resolved the disputes and the parties themselves requested appropriate orders, continuation of the multiple proceedings would serve no useful purpose.
The Court therefore gave effect to the Settlement Agreement and brought the pending litigation to an end.
2. Exercise of Article 142 jurisdiction
The important legal aspect of the order is the exercise of Article 142 of the Constitution.
The parties were no longer desirous of continuing their marital relationship and had remained separated since 2016. Taking these circumstances into account, the Supreme Court exercised its constitutional power and ordered that:
the marriage between Minhaz Ahmed and Ruana Rahman shall stand dissolved by way of a decree of divorce.
Thus, the Court did not merely dispose of the Transfer Petition; it also granted substantive matrimonial relief by dissolving the marriage.
3. Effect of settlement on connected proceedings
The settlement covered proceedings of different kinds—criminal, civil, departmental and writ proceedings. The Supreme Court gave comprehensive effect to the settlement by directing that all the identified proceedings stand quashed/disposed of in terms of the settlement.
The order therefore demonstrates the Court's approach to achieving a complete and final quietus to a matrimonial dispute where the parties have genuinely resolved their differences.
CONCLUSION
The Supreme Court held that, in view of the successful mediation and comprehensive settlement, there was no purpose in keeping alive the various proceedings between the parties.
Accordingly:
- I.A. No.108198/2026 was allowed.
- The specified criminal proceedings, civil proceedings, departmental proceedings and writ petition were quashed/disposed of in terms of the Settlement Agreement.
- The parties having decided not to continue their marital relationship and having lived separately since 2016, the Supreme Court exercised Article 142 jurisdiction.
- The marriage between Minhaz Ahmed and Ruana Rahman was dissolved by decree of divorce.
- The Registry was directed to prepare the decree of divorce in terms of the order.
- The Transfer Petition was accordingly disposed of and pending applications, if any, were also disposed of.
CORE RATIO / PROPOSITION
Where spouses have amicably and comprehensively settled their matrimonial disputes through mediation, have agreed to discontinue their marital relationship, and have been living separately for a substantial period, the Supreme Court may, in exercise of its jurisdiction under Article 142 of the Constitution, dissolve the marriage by decree of divorce and bring to an end the connected criminal, civil, departmental and writ proceedings so as to give complete and effective quietus to the dispute.
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