High Court May Quash Criminal Proceedings After Genuine Settlement in Personal Disputes Without Societal Impact

The petitioners sought quashing of Case Crime/F.I.R. No. 345 of 2026, registered at Police Station Jaspur, District Udham Singh Nagar, under Sections 115(2), 351(2), 352 and 69 of the Bharatiya Nyaya Sanhita, 2023 (“BNS”).

The complainant alleged that Petitioner No. 1 had maintained a relationship with her for approximately three years, established physical relations on a false promise of marriage, and later refused to marry her.

During the proceedings, the parties entered into a voluntary compromise and filed a supported compounding application.

The complainant appeared before the Court, stated that the dispute had arisen due to misunderstanding, confirmed that it had been amicably resolved, and expressed no objection to quashing the FIR and consequential proceedings.

The State opposed the prayer for quashing but did not dispute the compromise.

Whether the High Court could exercise its jurisdiction under Article 226 of the Constitution to quash the FIR and consequential criminal proceedings on the basis of a genuine and voluntary settlement between the parties

Whether, considering the personal nature of the dispute, the complainant’s unequivocal withdrawal of her grievance, and the settlement, continuation of the prosecution would serve any useful purpose

The Court exercised its extraordinary jurisdiction under Article 226 of the Constitution to consider quashing of criminal proceedings.

Relying on Gian Singh v. State of Punjab, (2012) 10 SCC 303; Narinder Singh v. State of Punjab, (2014) 6 SCC 466; and State of Madhya Pradesh v. Laxmi Narayan, (2019) 5 SCC 688, the Court applied the principle that criminal proceedings may be quashed where the dispute has an overwhelmingly personal, civil, commercial or matrimonial character and the parties have genuinely settled it, provided the offences are not heinous or of such a nature as to seriously affect society or public interest.

The FIR allegations concerned Sections 115(2), 351(2), 352 and 69 of the BNS.

The Court treated the dispute as arising from a personal relationship between the complainant and Petitioner No. 1.

It verified the compromise by interacting with the complainant in open court and found that she had voluntarily settled the matter, had no subsisting grievance, and did not wish to pursue the prosecution.

The compromise application and supporting affidavits further indicated that the settlement was free from coercion, pressure, inducement or undue influence.

Applying the principles in Gian Singh, Narinder Singh and Laxmi Narayan, the Court concluded that the possibility of conviction had substantially diminished and that continuation of the proceedings would constitute unnecessary criminal litigation rather than advance the ends of justice.

The criminal writ petition was accordingly allowed, and any pending applications were disposed of.