Existence of factual disputes and non-compoundable allegations of human trafficking preclude quashing of criminal proceedings.

The petitioners, owners of a brick manufacturing business, sought the quashing of FIR No. 148/2019 and the subsequent charge-sheet No. 143/2025.

The complainant alleged that in 2018, the accused induced several laborers to travel from Chhattisgarh to Uttar Pradesh with promises of high wages, only to subject them to ill-treatment, illegal confinement, and bonded labor.

The petitioners contended that the accusations were false, arising from a dispute over laborers consuming alcohol and performing poorly despite receiving advance wages.

They further highlighted that they had been granted anticipatory bail and that an amicable compromise had been reached with the complainant.

Whether the FIR and criminal proceedings under Sections 370(3), 342, 374, 506, and 34 of the IPC should be quashed on the grounds of a private compromise and lack of prima facie evidence.

Whether the High Court, under Section 482 Cr.P.C. (Section 528 BNSS), can conduct a mini-trial to adjudicate the veracity of the petitioners' factual defenses at the preliminary stage.

The Court applied the inherent powers of the High Court under Section 482 Cr.P.C. (now Section 528 BNSS) to prevent abuse of the process of law.

It relied on the principle that non-compoundable offences with serious societal impacts, particularly those involving human trafficking (Section 370 IPC) and forced labor, cannot be quashed solely on the basis of a private compromise.

Furthermore, the Court adhered to the established precedent that factual defenses (such as payment of wages or worker misconduct) are matters of evidence for trial and cannot be adjudicated in a quashing petition if the FIR discloses a cognizable offence.

The Court observed that the FIR and Section 161 Cr.P.C. statements provided specific allegations of inducement, exploitation, and coercion, which prima facie constitute the alleged offences.

Regarding the petitioners' defense—that the dispute was civil/contractual and the workers were problematic—the Court reasoned that these are evidentiary matters requiring a trial and cannot be determined at the threshold.

Critically, the Court rejected the argument for quashing based on a compromise, noting that human trafficking and forced labor are not mere private disputes but "serious societal impacts".

The Court emphasized that its inherent power must be exercised sparingly and only when no offence is disclosed; here, the material collected during the investigation justified a continued prosecution.

The High Court refused to quash the FIR or the criminal proceedings, stating that the grant of anticipatory bail or a private settlement does not mandate the termination of a trial for non-compoundable societal crimes.

The petition was dismissed.