### High Court exercises inherent power to quash non-compoundable Section 354 IPC proceedings following mutual settlement between neighbors.

The petitioners moved the High Court seeking the quashing of FIR No. 762/2016, registered under Sections 323/341/354/34 of the IPC at PS Shahbad Dairy.

The FIR arose from a physical altercation on October 20, 2016, between neighbors, during which it was alleged that Petitioners No. 1 and 2 outraged the modesty of the complainant (Respondent No. 2).

A chargesheet was subsequently filed.

During the pendency of the proceedings, the parties executed a Compromise Deed dated May 13, 2025, stating they had settled all disputes out of free will.

Additionally, a cross-FIR (No. 763/2016) filed by the petitioners against the respondents had already been quashed by the Court on November 26, 2025.

Whether the High Court should exercise its inherent power to quash criminal proceedings involving a non-compoundable offence (Section 354 IPC) on the basis of a private settlement between the parties.

The court applied Section 528 of the Bhartiya Nagarik Suraksha Sanhita, 2023 (formerly Section 482 of the CrPC) regarding the inherent powers of the High Court to prevent abuse of process and secure the ends of justice.

It relied on the principles established in *Narinder Singh & Ors. v. State of Punjab & Anr.* (2014) 6 SCC 466, which held that cases of a predominantly private nature should be quashed if settlement is reached and conviction is remote.

It further cited *Parbatbhai Aahir & Ors. v. State of Gujarat & Anr.* (2017) 9 SCC 641, emphasizing that while heinous crimes (murder/rape) cannot be quashed, the Court must evaluate if the ends of justice justify quashing in other matters based on the facts and circumstances of each case.

The Court observed that while Section 354 of the IPC is non-compoundable under Section 320 CrPC, the High Court possesses the inherent power to quash such proceedings to prevent the abuse of the court's process.

The Court noted that the parties are immediate neighbors who have resolved their misunderstandings and are now residing cordially in the same vicinity.

Applying the *Narinder Singh* guidelines, the Court found that the dispute was essentially private and not a "heinous" crime of mental depravity that would impact society at large.

Given that the cross-FIR had already been quashed and the complainant stated she had no surviving grievances, the Court reasoned that the possibility of conviction was remote and bleak.

Continuance of the trial would merely foster ill will and cause unnecessary harassment to both parties.

The Court quashed FIR No. 762/2016 and all consequential proceedings arising therefrom, noting that the settlement would secure the ends of justice and allow the parties to live peacefully.