High Court exercises inherent powers to quash non-compoundable criminal proceedings based on voluntary settlement between parties.

The petitioners filed a petition under Section 528 of the Bhartiya Nagarik Suraksha Sanhita (BNSS) [formerly Section 482 Cr.P.C.] seeking to quash FIR Crime No. 145/2024 registered at Police Station Badoni, District Datia.

The FIR alleged offences under Sections 307 (Attempt to murder), 323, 294, 34, and 195-A of the IPC, along with provisions of the SC/ST (Prevention of Atrocities) Act and the Arms Act.

During the pendency of the case, the petitioners and respondents No. 2 to 5 filed applications (I.A. No. 1710/2026 and 1711/2026) stating they had resolved their disputes amicably.

The factum of this voluntary compromise was verified by the Principal Registrar of the High Court on 27.01.2026.

1. Whether the High Court, in the exercise of its inherent powers, can quash criminal proceedings for non-compoundable offences on the basis of a compromise between the parties to prevent an abuse of the process of law.

The court primarily applied Section 528 of the BNSS regarding the inherent powers of the High Court.

It relied on the landmark precedent of Gian Singh v. State of Punjab (2012), which established that the High Court’s power to quash proceedings under inherent jurisdiction is distinct from the power of compounding under Section 320 Cr.P.C.

It further integrated principles from Narinder Singh v. State of Punjab (2014) and State of M.P. v. Laxmi Narayan (2019), which distinguish between "heinous and serious offences" (like murder or rape) and those that are predominantly private or civil in nature, where quashing is permissible to secure the ends of justice.

The court also cited K. Bharthi Devi v. State of Telangana (2024) highlighting that family or matrimonial disputes reaching a settlement justify quashing.

The Court examined the nature of the dispute and the validity of the settlement reached between the accused and the victims.

Applying the ratio of Laxmi Narayan, the court noted that while Section 307 IPC is generally serious, the High Court possesses the power to quash proceedings if the dispute is essentially personal and the parties have resolved it voluntarily.

The court reasoned that since the parties entered into a compromise without threat or coercion, as verified by the Principal Registrar, continuing the prosecution would be a "futile exercise" and a waste of judicial time.

The court determined that the settlement rendered the possibility of conviction remote, and thus, quashing was necessary to prevent the abuse of the process of law.

The court held that in light of the amicable resolution and established Supreme Court precedents, the further trial would serve no purpose and would result in a wasteful exercise for the judiciary.

No order as to costs was made.