High Court exercises inherent powers to quash non-compoundable fraud proceedings based on voluntary private compromise.

The applicant filed a petition seeking the quashment of FIR/Crime No. 405/2025 registered at Police Station Saman, District Rewa, for offences under Sections 420, 467, 468, and 471 of the IPC.

During the pendency of the proceedings, the applicant and respondent No. 2 (the complainant) entered into an amicable settlement.

Pursuant to a court order dated 06.04.2026, the Registrar (Judicial-II) verified the compromise and submitted a report dated 15.04.2026, confirming that the settlement was voluntary, genuine, and executed without coercion.

1. Whether the High Court should exercise its inherent powers to quash criminal proceedings for non-compoundable offences on the basis of a compromise when the dispute is private in nature.

The court primarily applied Section 528 of the Bhartiya Nagarik Suraksha Sanhita, 2023 (BNSS), which pertains to the inherent powers of the High Court.

It relied on the precedent established in Gian Singh v. State of Punjab and Another (2012) 10 SCC 303, which held that the High Court may quash criminal proceedings involving non-compoundable offences if they are overwhelmingly of a private, civil, or commercial nature and a compromise makes the possibility of conviction remote.

The Court observed that the allegations in the FIR arose from financial and transactional dealings, characterizing the dispute as essentially private and personal rather than one impacting public interest.

Relying on the verification report from the Registrar (Judicial-II), the Court satisfied itself that the parties had resolved their dispute of their own free will.

Applying the principles from Gian Singh, the Court reasoned that since a full settlement had been reached, the likelihood of conviction was bleak, and continuing the criminal proceedings would constitute an abuse of the process of law and cause extreme injustice to the applicant.

The Court held that the compromise was bona fide and deserved acceptance. Consequently, I.A. No. 6403/2026 (leave to compound) and I.A. No. 6404/2026 (compromise) were allowed, the applicant was discharged, and all bail bonds were cancelled.