High Court may quash criminal proceedings for amicable settlement of private, non-heinous disputes.

The petitioners filed a criminal writ petition under Article 226 of the Constitution seeking quashing of FIR/Case Crime No. 0246 of 2026, registered at Police Station Bhadarabad, District Haridwar, under Sections 115(2), 318(4), 351(3) and 352 of the Bharatiya Nyaya Sanhita, 2023 (“BNS”), along with a direction restraining the State authorities from harassing or arresting them in connection with the FIR.

The FIR was lodged by respondent no. 3, alleging, inter alia, that the petitioners had, pursuant to a criminal conspiracy, misappropriated money belonging to him. During the proceedings, the parties entered into an amicable settlement and filed a joint compounding application supported by their affidavits, stating that they did not wish to pursue the criminal proceedings.

Respondent no. 3 appeared through video conferencing, was identified by his counsel, confirmed the settlement as voluntary and free from coercion, and stated that he had no objection to quashing the FIR and consequential proceedings. He further stated that ₹15,10,000 had been misappropriated from him and four other persons and that the dispute had been settled.

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 an amicable settlement between the parties

Whether, in view of the voluntary settlement and the complainant’s lack of objection, continuation of the criminal proceedings would amount to an abuse of the process of law

The Court exercised its extraordinary jurisdiction under Article 226 of the Constitution to secure the ends of justice and prevent abuse of the process of law.

It relied 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, which establish that criminal proceedings arising from private or personal disputes may be quashed where the parties have genuinely and voluntarily settled their differences, the possibility of conviction is remote, and the offences do not involve heinous crimes or matters having a serious impact on society at large.

The proceedings concerned allegations under Sections 115(2), 318(4), 351(3) and 352 of the BNS.

The Court verified the settlement through the statement of respondent no. 3, who appeared before it, was identified by counsel, and expressly confirmed that the compromise was entered into voluntarily and without coercion, undue influence or pressure.

Since the dispute was essentially private and personal, and the complainant no longer wished to pursue the prosecution, the Court applied the principles in Gian Singh, Narinder Singh and Laxmi Narayan.

It found that the settlement was genuine and that continuation of the criminal proceedings would serve no useful purpose and would amount to an abuse of the process of law.

The Court therefore accepted the compounding application despite the proceedings being pursued through the High Court’s inherent/constitutional jurisdiction.

The joint compounding application, I.A. No. 1 of 2026, was allowed.

FIR/Case Crime No. 0246 of 2026, registered at Police Station Bhadarabad, District Haridwar, under Sections 115(2), 318(4), 351(3) and 352 of the BNS, together with all consequential proceedings, was quashed qua the petitioners.

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