A private compromise cannot justify quashing prosecution for serious, non-compoundable attempt-to-murder allegations.

The petitioner sought quashing under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (“BNSS”), corresponding to Section 482 Cr.P.C., of FIR No. 076 dated 17.03.2026 registered at Police Station Urban Estate, Hisar, under Sections 109(1), 115, 118(1), 296 and 351(3) of the Bharatiya Nyaya Sanhita, 2023, corresponding to Sections 307, 323, 324, 294 and 506 IPC, together with all consequential proceedings.

The FIR alleged that, following a dispute regarding salary payment and prior animosity, the petitioner came to the complainant’s workplace, abused him, inflicted knife blows on his abdomen and chest, and threatened to kill him; the complainant was thereafter admitted to hospital in an unconscious condition.

During the proceedings, the parties executed a compromise dated 13.08.2026, and the complainant consented to quashing of the FIR.

The State opposed the petition on the ground that the allegations disclosed a serious, non-compoundable offence involving a direct knife assault and that the petitioner’s earlier regular-bail application had been dismissed by the High Court on 22.07.2026.

1. Whether the FIR and the material collected during investigation disclosed cognizable offences and constituted a case warranting continuation of criminal proceedings, or instead fell within the recognised categories for quashing under the inherent jurisdiction of the High Court.

2. Whether the subsequent compromise between the petitioner and the complainant justified quashing of the FIR and proceedings involving an allegation under Section 307 IPC, a non-compoundable offence, under Section 528 BNSS.

The Court applied Section 528 BNSS, corresponding to Section 482 Cr.P.C., which confers inherent jurisdiction on the High Court to prevent abuse of the process of court and secure the ends of justice.

It relied on *R.P. Kapur v. State of Punjab*, AIR 1960 SC 866, and *State of Haryana v. Ch. Bhajan Lal*, 1991 (1) RCR (Criminal) 383, under which quashing may be exercised in exceptional cases where the allegations do not constitute an offence, do not disclose a cognizable offence, are inherently absurd or improbable, are legally barred, or are manifestly mala fide, but the power must be exercised sparingly and with circumspection.

The Court further relied on *M/s Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra*, (2021) 19 SCC 401, holding that the High Court should not conduct a mini-trial, assess the reliability of evidence, decide disputed facts, or examine the defence while considering quashing of an FIR.

The Court also applied the principle that serious and non-compoundable offences, particularly those involving an alleged attempt on a person’s life and an element of public wrong, cannot ordinarily be quashed solely on the basis of a private compromise.

The Court held that the FIR, read with the investigation material, prima facie disclosed cognizable offences and that the allegations, if accepted at face value, constituted the offences alleged.

The petitioner was specifically named and attributed a direct role in inflicting knife blows on the complainant’s abdomen and chest, allegedly with the intention to cause death.

The allegations were neither absurd, inherently improbable, frivolous, nor demonstrably mala fide, and therefore did not satisfy any of the *Bhajan Lal* categories for quashing.

Although the complainant had voluntarily entered into a compromise and raised no objection, the Court found that the alleged knife assault and invocation of Section 307 IPC transcended a purely private dispute and implicated public peace, safety, and the administration of criminal justice.

Consequently, the compromise could not efface the prima facie criminality or justify termination of the prosecution at the FIR stage.

The petition seeking quashing of FIR No. 076 dated 17.03.2026 and all consequential proceedings was dismissed, as no exceptional circumstance, manifest illegality, or abuse of process was established.

The pending miscellaneous, interlocutory, and ancillary applications were disposed of accordingly.

The Court clarified that its observations were confined to the quashing petition and would not affect the merits of the prosecution or the defence; the Trial Court was directed to decide the case independently on the basis of the evidence and in accordance with law.