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FIR Filed In Grief After Daughter’s Death, Father Later Settles With In-Laws; Uttarakhand HC Quashes the Dowry Death Case

FIR Filed In Grief After Daughter’s Death, Father Later Settles With In-Laws; Uttarakhand HC Quashes the Dowry Death Case

Deepanshu Mittal & Ors. v. State of Uttarakhand, WPCRL No. 1627 of 2026 [Order dated August 24, 2026]

Uttarakhand HC Quashes Dowry Case

The Uttarakhand High Court has quashed an FIR lodged by a father against his deceased daughter’s husband and family members, after a jointly signed compounding application by the deceased’s father and the petitioners, supported by their respective affidavits, was filed before the Court. The case was heard by Justice Alok Mahra.

The case arose from an FIR lodged by the father of the deceased woman, alleging that she was subjected to dowry-related harassment and cruelty. The complaint further alleged that, after she delivered a female child, when she conceived for the second time, a prenatal sex determination test was conducted and, upon learning that the foetus was female, the pregnancy was terminated. It was further alleged that her health deteriorated due to inadequate medical treatment and that she died on July 11, 2025.

The petitioners’ counsel argued that the FIR was lodged after an unexplained delay of around three months and contained general allegations without attributing any specific overt act to the individual petitioners. Counsel also submitted that the deceased had developed serious medical complications and that, despite the best efforts of the petitioners and her father, she could not be saved. It was further submitted that the father, being deeply attached to his daughter, had been under severe emotional distress following her death when the FIR was lodged.

A jointly signed compounding application, supported by affidavits of the petitioners and the deceased’s father, was subsequently filed. The petitioners submitted that the parties had entered into a settlement and sought compounding of the matter.

The deceased’s father appeared before the Court and stated that he had been under “considerable emotional distress and mental anguish” following his daughter’s death when he lodged the FIR. He subsequently realised, according to his statement recorded by the Court, that she had suffered serious medical complications which resulted in her death.

He said he no longer wished to pursue the criminal proceedings and wanted the matter to be brought to an end so that the parties could restore peace and harmony and move forward. Both sides made statements that they wanted to close the matter in view of the settlement.

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Referring to tn the Supreme Court’s judgments in Gian Singh v. State of Punjab, (2012) 10 SCC 303 and Narinder Singh & Ors. v. State of Punjab & Anr., (2014) 6 SCC 466, the High Court held that, following the compromise, the possibility of the trial resulting in conviction was remote and bleak. It further held that continuation of the criminal proceedings would cause oppression, prejudice and injustice and amount to an abuse of the process of law.

The High Court accordingly allowed the writ petition and quashed the FIR registered under Section 80 of the BNS at Police Station Transit Camp, Udham Singh Nagar, along with all proceedings emanating from it.

Appearances

Mr. Vikas Kumar Guglani, Advocate for the petitioners.

Mr. S.C. Dumka, A.G.A. and Mr. Nikhil Bisht, Brief Holder for the State of Uttarakhand.

Mr. Rohit Arora, Advocate for respondent no.3.

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Deepanshu Mittal & Ors. v. State of Uttarakhand

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