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

The petitioner filed a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) [formerly Section 482 CrPC] seeking the quashment of FIR Crime No. 319/2025 registered at Police Station Civil Lines, Datia, for offences under Sections 109(1) and 296-A of the Bharatiya Nyaya Sanhita (BNS).

During the pendency of the proceedings, the parties filed interlocutory applications (I.A. Nos. 746/2026 and 747/2026) stating they had reached a voluntary settlement.

Following a court order dated 19.01.2026, the Principal Registrar verified the compromise and reported that the parties settled the dispute without any threat or coercion.

1. Whether the High Court can exercise its inherent powers to quash criminal proceedings in non-compoundable cases based on a private settlement between the parties.

2. Whether the continuation of prosecution in the present matter would constitute an abuse of the process of law given the amicable resolution between the petitioner and the complainant.

The Court primarily applied Section 528 of the BNSS regarding the inherent powers of the High Court to prevent abuse of the process of law.

It relied on *Gian Singh v. State of Punjab (2012)*, which distinguished between "compounding" under Section 320 and "quashing" under inherent powers.

Reliance was placed on *State of M.P. v. Laxmi Narayan (2019)*, which established that proceedings with a predominantly civil or matrimonial flavor may be quashed if the parties resolve the dispute, provided the offence is not heinous (e.g., murder or rape).

Further reliance was placed on *K. Bharthi Devi v. State of Telangana (2024)* and *Daxaben v. State of Gujarat (2022)* to affirm that quashing is justified to secure the ends of justice in personal or commercial disputes.

The Court observed that the dispute between the parties had been resolved voluntarily, as verified by the Principal Registrar’s report.

Applying the principles from *Gian Singh* and *Laxmi Narayan*, the Court reasoned that since the matter had been settled amicably and did not fall under the category of "heinous and serious offences" that impact society at large, the power to quash should be exercised.

The Court found that the offences charged under the BNS in this instance were essentially private or personal in nature.

Consequently, it determined that forcing the parties to continue with the trial would be a "futile exercise" and a waste of judicial time.

The petition was allowed; the Court ordered the quashment of FIR bearing Crime No. 319/2025 at Police Station Civil Lines, District Datia, along with all consequential criminal proceedings initiated against the petitioner.

No order as to costs was made.