Criminal proceedings may be quashed on compromise where a private dispute makes conviction remote and continuation abusive.

The petitioner sought quashing of FIR/Case Crime No. 384 of 2025, registered at Police Station Haldwani, District Nainital, for offences under Sections 117(2) and 352 of the Bharatiya Nyaya Sanhita, 2023 (“BNS”).

The FIR alleged that, during an altercation, the petitioner abused and assaulted respondent no. 3/complainant and struck him on the left ear, allegedly resulting in rupture of the eardrum and hospitalisation.

During the proceedings, the parties entered into an amicable settlement and filed a compounding application supported by separate affidavits, stating that the compromise was voluntary and free from coercion or undue influence.

The petitioner and complainant appeared through video conferencing and confirmed the settlement before the Court; the complainant stated that he no longer wished to prosecute the petitioner.

The State opposed the petition but did not dispute the compromise.

The Court found that the incident arose from a sudden scuffle between rival students of the same college and was not apparently premeditated.

Whether the High Court could exercise its extraordinary jurisdiction under Article 226 of the Constitution to quash the FIR and consequential criminal proceedings on the basis of an amicable settlement between the accused and the complainant?

Whether, in view of the voluntary compromise, the private nature of the dispute, and the absence of apparent premeditation, continuation of the criminal proceedings would amount to an abuse of the process of law?

The Court exercised its extraordinary jurisdiction under Article 226 of the Constitution to consider quashing of the FIR and consequential proceedings.

It relied on Gian Singh v. State of Punjab, (2012) 10 SCC 303, and Narinder Singh v. State of Punjab, (2014) 6 SCC 466, which recognise that criminal proceedings may be quashed on the basis of a genuine settlement where the dispute is predominantly private or personal in nature, the compromise is voluntary, the possibility of conviction is remote and bleak, and continuation of the proceedings would amount to an abuse of the process of law or cause unnecessary oppression and prejudice to the parties.

The proceedings arose from allegations under Sections 117(2) and 352 of the BNS.

The Court verified the voluntary nature of the settlement through the affidavits, the compounding application, and the parties’ statements made through video conferencing.

It treated the incident as the result of a sudden altercation between rival students rather than a premeditated assault.

In light of the complainant’s unwillingness to prosecute, the private character of the dispute, and the parties’ amicable resolution, the Court concluded that the likelihood of conviction was remote and bleak.

Accordingly, continuation of the prosecution would serve no meaningful purpose and would cause unnecessary harassment and prejudice to the petitioner, thereby constituting an abuse of the process of law.

FIR/Case Crime No. 384 of 2025, registered at Police Station Haldwani, District Nainital, along with all consequential proceedings, was quashed on the basis of the voluntary settlement between the parties.

The compounding application and any pending applications were disposed of accordingly.