High Court may quash non-compoundable criminal proceedings under inherent powers where parties resolve personal disputes amicably.

The petitioner filed a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) seeking the quashment of FIR Crime No. 01/2023 registered at Police Station Gwalior for offences under Sections 294, 323, and 506 of the IPC.

During the proceedings, the petitioner and respondent No. 2 filed applications (I.A. Nos. 26450/2025 and 26451/2025) stating they had reached an amicable settlement.

The factum of this compromise was verified by the Principal Registrar of the High Court, who reported that the parties entered the settlement voluntarily and without coercion.

1. Whether the High Court can exercise its inherent powers to quash criminal proceedings for non-compoundable offences on the basis of a private settlement between the parties.

2. Whether the continuation of prosecution in the present case would amount to an abuse of the process of law given the voluntary compromise.

The court primarily applied Section 528 of the BNSS regarding the inherent powers of the High Court.

It relied on the landmark precedent of Gian Singh v. State of Punjab, which distinguished between the "compounding of offences" under Section 320 Cr.P.C. and the "quashing of proceedings" under inherent powers to secure the ends of justice.

The court further applied principles from State of M.P. v. Laxmi Narayan, which established that proceedings involving non-compoundable offences of a civil, mercantile, or matrimonial nature may be quashed if the dispute is settled, provided they do not involve heinous crimes like murder or rape.

Additional reliance was placed on K. Bharthi Devi v. State of Telangana regarding the breadth of inherent powers in personal disputes.

Additional reliance was placed on Daxaben v. State of Gujarat regarding the breadth of inherent powers in personal disputes.

The Court examined the nature of the offences (Sections 294, 323, 506 IPC) and the verification report submitted by the Principal Registrar.

It reasoned that since the dispute was essentially private and the parties had resolved their grievances voluntarily, the possibility of conviction was remote.

Applying the ratio from Gian Singh and Laxmi Narayan, the Court determined that the offences charged were not "heinous" or of "mental depravity" affecting society at large, but were instead personal in nature.

Consequently, the Court found that forcing the trial to continue would be a "futile exercise" and a waste of judicial time.

The Court allowed the petition and ordered the quashment of FIR Crime No. 01/2023 and all consequential proceedings arising therefrom.

No order as to costs was made.