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

The petitioners were convicted by the Trial Court on December 24, 2024, for offences under Sections 147, 148, 452, 323 r/w 149, and 427 r/w 149 of the IPC

During the pendency of their appeal before the Additional Sessions Judge, Chourai, the parties (who are relatives and neighbors) filed a joint compromise application under Sections 359(1) and 359(8) of the BNSS, 2023

On November 17, 2025, the Appellate Court recorded the parties' statements but deferred the consideration of the compromise until the final judgment

The petitioners approached the High Court seeking quashment of the proceedings and acquittal based on the settlement

1. Whether the High Court can exercise its inherent powers to quash criminal proceedings and acquit the accused for non-compoundable offences on the basis of a compromise between parties

2. Whether the continuation of criminal proceedings in a settled dispute between relatives constitutes an abuse of the process of law

Section 482 of the Code of Criminal Procedure (Cr.P.C.) regarding the inherent powers of the High Court to prevent abuse of the process of law

Unnikrishnan @ Ummikuttan vs. State of Kerala (AIR 2017 SC 1745), which established that even if an offence is non-compoundable under Section 320 Cr.P.C., the Court may, in view of a compromise, quash proceedings or reduce sentences to meet the ends of justice

Bharath Singh vs. State of M.P. and Ramlal vs. State of J & K regarding the judicial discretion to allow compounding in non-compoundable cases depending on facts and circumstances

The Court observed that the parties had amicably resolved their private dispute and finalized a compromise before the first appellate court

Justice B.P. Sharma reasoned that since the complainant and petitioners are relatives living in the same locality, the settlement was intended to "put a quietus to the matter"

Applying the principles from Unnikrishnan (supra), the Court held that while the power to quash non-compoundable offences must be exercised with caution regarding the gravity of the offence, the present case justified intervention

It determined that because the complainant no longer intended to support the prosecution, continuing the trial would be an "exercise in futility" and an "abuse of the process of law"

The High Court set aside the impugned orders of both the Trial Court (dated 24.12.2024) and the Appellate Court (dated 17.11.2025). Consequently, the petitioners were acquitted of all charges under Sections 147, 148, 149, 452, 294, 323/34, and 427 of the IPC