High Court exercises inherent powers under Section 528 BNSS to quash non-compoundable SC/ST Act offences based on voluntary compromise.

The petitioners filed a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) [corresponding to Section 482 of the Cr.P.C.] seeking the quashment of FIR Crime No. 22/2026 registered at Police Station Badoni, District Datia.

The FIR alleged offences under Sections 296(A), 115(2), 351(2), and 3(5) of the Bharatiya Nyaya Sanhita (BNS), along with Sections 3(1)(d), 3(1)(dh), and 3(2)(va) of the SC/ST (Prevention of Atrocities) Act.

During the pendency of the proceedings, the parties filed applications (I.A. Nos. 3253/2026 & 3254/2026) stating they had voluntarily resolved their private dispute through a compromise.

The factum of the compromise was verified and confirmed by the Principal Registrar of the High Court.

Whether the High Court, in the exercise of its inherent powers, can quash criminal proceedings involving non-compoundable offences on the basis of a voluntary settlement between the parties.

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

It relied on the landmark precedent *Gian Singh v. State of Punjab* (2012) 10 SCC 303, which established that the High Court’s power to quash proceedings is distinct from the power to compound offences under Section 320.

It further applied *Narinder Singh v. State of Punjab* (2014) 6 SCC 466 and *State of M.P. v. Laxmi Narayan* (2019) 5 SCC 688, which held that while serious/heinous crimes cannot be quashed, proceedings arising out of civil, matrimonial, or private disputes can be quashed if a settlement is reached and further prosecution would be futile.

The Court observed that the dispute between the petitioners and respondents was essentially private in nature and had been resolved amicably.

Although some of the charged offences were non-compoundable, the Court reasoned that since the parties had entered into a voluntary 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.

By applying the principles laid down in *Laxmi Narayan*, the Court determined that this case did not fall under the category of "heinous and serious offences of mental depravity" that impact society at large, thereby justifying the invocation of inherent powers to secure the ends of justice.

Consequently, the High Court allowed the petition, quashing FIR Crime No. 22/2026 and all consequential proceedings flowing therefrom.

No order was made as to costs.