Criminal proceedings against subsequent purchasers were quashed after settlement and execution of a confirmation deed.

Respondent No. 2 alleged that property belonging to her uncle had been bequeathed to her and two others, but that a third party, Khaleel Ulla, had fabricated an unregistered power of attorney and dealt with the property.

The petitioners were subsequent purchasers. On her complaint, Bannerghatta Police registered Crime No. 185/2025 for offences under Sections 420, 465, 468 and 471 IPC. The petitioners sought quashing of the FIR under the Court’s inherent jurisdiction, and a stay had been granted during the proceedings.

While the petition was pending, the parties settled: respondent No. 2 received ₹1 crore and executed a registered confirmation deed confirming the petitioners’ sale deed. The parties appeared before the Court and confirmed the arrangement.

1. Whether the criminal proceedings against the petitioners could be terminated on the basis of the parties’ settlement and the confirmation deed.

2. Whether the allegations, considered alongside the settlement, justified continuation of the proceedings against the petitioners as subsequent purchasers.

The Court considered the compounding application under Section 359(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023, read with its inherent jurisdiction under Section 528 BNSS, and the alleged offences under Sections 420, 465, 468 and 471 of the Indian Penal Code.

It applied those provisions to allow compounding and quash the FIR.

The judgment cites no precedent or separately articulates a broader legal test.

The Court noted that the alleged fabrication concerned a power of attorney attributed to Khaleel Ulla, while the petitioners were subsequent purchasers. Respondent No. 2 had received ₹1 crore and executed a registered confirmation deed in their favour, and the petitioners confirmed the settlement before the Court.

In those circumstances, the Court considered that the allegations, even if taken into account, were directed against Khaleel Ulla rather than the petitioners; it concluded that continuing the proceedings against the petitioners would cause them prejudice and injury.