A compromise cannot justify quashing serious attempt-to-murder proceedings involving firearm use.

The petitioners sought to quash FIR No. 215/2026, registered at Police Station Mehagaon, District Bhind, for offences under Sections 109(1), 296(b) and 3(5) of the Bharatiya Nyaya Sanhita (BNS), and the consequential proceedings, invoking Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) on the basis of a compromise.

The FIR alleged that, following a dispute over an unpaid amount for petrol and diesel, the accused took the complainant away from a petrol pump and one of them fired a gunshot that struck the left side of the complainant’s head.

The parties filed compromise applications supported by affidavits; the Principal Registrar verified that the compromise was voluntary.

The complainant supported the petition, while the State opposed it.

Whether the FIR and consequential proceedings alleging a firearm attack with intent to cause death could be quashed under Section 528 BNSS because the parties had compromised.

Whether the nature and gravity of the alleged offence, and the public interest in prosecution, precluded quashing despite the complainant’s willingness to settle.

Section 528 BNSS confers inherent jurisdiction to prevent abuse of process and secure the ends of justice, but compromise alone does not justify quashing proceedings involving serious offences with a societal impact.

In State of Madhya Pradesh v. Laxmi Narayan, (2019) 5 SCC 688, the Supreme Court held that heinous or serious offences, including attempt to murder, should not ordinarily be quashed merely on settlement; the court must consider whether the allegation is supported by the evidence and circumstances.

The Court also relied on Vijay Kumar Kela & Anr. v. Central Bureau of Investigation & Anr., 2026 INSC 588, for the principle that the nature and gravity of the offence and the public interest in prosecuting serious crimes must be considered when deciding whether to quash on the basis of settlement.

The allegations at the FIR stage were that the accused used a firearm and fired at the complainant with the intention of causing his death, striking him in the head.

The Court considered these allegations indicative of a serious offence involving an attempt on life, not a dispute of an overwhelmingly private or civil character.

Applying the principles in Laxmi Narayan and Vijay Kumar Kela, it held that the subsequent compromise did not remove the seriousness of the alleged offence or the public interest in its prosecution.

It dismissed the petition and disposed of I.A. Nos. 17783/2026 and 17784/2026; it clarified that its observations would not prejudice either party before the Trial Court.