Criminal proceedings arising from private disputes may be quashed upon compromise where conviction is improbable.

The petitioner sought the quashing of criminal proceedings and an order taking cognizance dated 17.11.2022 passed by the CJM, Godda, in connection with Godda (Town) P.S. Case No. 637 of 2015.

The petitioner was charged under Sections 420, 406, 120B, and 34 of the IPC, and Sections 3, 4, and 6 of the Prize Chits and Money Circulation Schemes (Banning) Act.

While the case was pending for appearance, the petitioner and the informant (Opposite Party No. 2) filed Interlocutory Application No. 2661 of 2026, supported by affidavits, stating they had reached a voluntary compromise through well-wishers.

Both parties jointly submitted that the dispute was private in nature and the informant no longer wished to proceed.

1. Whether the High Court should exercise its inherent power to quash criminal proceedings in non-compoundable cases based on a private settlement between the parties.

2. Whether the continuation of the criminal proceedings, despite a compromise, would amount to an abuse of the process of law.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (formerly Section 482 of the Cr.P.C.), which saves the inherent power of the High Court to prevent abuse of the process of any court or to secure the ends of justice.

The landmark precedent Parbatbhai Aahir @ Parbatbhai Bhimsinhbhai Karmur & Others v. State of Gujarat & Another (2017) 9 SCC 641, which established that while heinous crimes cannot be quashed via settlement, cases with "overwhelmingly and predominatingly civil flavour" or private/personal disputes (commercial, financial, or matrimonial) can be quashed if the possibility of conviction is remote and bleak due to the compromise.

The Court observed that the offences involved were not heinous, nor did they involve "mental depravity" or impact public policy; rather, the matter was essentially a private dispute.

The Judge reasoned that because a complete settlement had been reached and the informant had filed an affidavit expressing no desire to prosecute, the likelihood of a conviction was now "remote and bleak".

Applying the Parbatbhai Aahir guidelines, the Court determined that forcing the petitioner to undergo a trial despite the settlement would result in "great oppression and prejudice" and would constitute an unwarranted drain on judicial resources.

The State also expressed no objection to the quashing in light of the compromise.

The Court allowed the petition and quashed the entire criminal proceedings, including the cognizance order dated 17.11.2022 in Godda (Town) P.S. Case No. 637 of 2015 (G.R. Case No. 1716 of 2015) against the petitioner.

Interlocutory Application No. 2661 of 2026 was disposed of accordingly.