High Court may quash non-compoundable offences of predominantly civil nature after genuine settlement.

Respondents Nos. 2 and 3 alleged that the applicants, pursuant to a criminal conspiracy, forged documents concerning jointly owned land at Gram Hukumkhedi, Survey No. 7/3/7, and instituted a false civil suit to unlawfully extract money from them.

Following an enquiry directed by senior police authorities, the complainants produced the relevant land-title documents, disputed agreement, possession receipt, and forensic report. Consequently, Crime No. 215/2024 was registered at Police Station Rajendra Nagar, Indore, for offences under Sections 420, 447, 465 and 120-B of the IPC.

During the proceedings, the applicants and Respondents Nos. 2 and 3 executed a Compromise Deed dated 21 August 2024, stating that no claims or counterclaims survived between them.

The compromise was verified before the Principal Registrar on 24 July 2026 and taken on record.

The applicants thereafter sought quashing of the FIR and all consequential proceedings under Section 528 of the BNSS, 2023.

Whether the High Court could exercise its inherent jurisdiction under Section 528 of the BNSS, 2023 to quash the FIR and consequential criminal proceedings on the basis of a settlement between the parties, notwithstanding that the alleged offences were not compoundable in the ordinary manner?

Whether the dispute, arising from allegations concerning forged land documents and a related civil suit, possessed an overwhelmingly civil character such that continuation of the criminal proceedings would be futile and contrary to the ends of justice?

The Court exercised its inherent jurisdiction under Section 528 of the BNSS, 2023 to consider quashing of the FIR and subsequent proceedings.

The alleged offences were under Sections 420, 447, 465 and 120-B of the IPC.

Relying on Gian Singh v. State of Punjab, the Court reiterated that quashing criminal proceedings on the basis of settlement is distinct from compounding under Section 320 CrPC; the High Court may quash proceedings where the dispute has been settled, continuation would be futile, and quashing is necessary to secure the ends of justice.

The power should not ordinarily be exercised for serious offences involving mental depravity, moral turpitude, or grave offences against society, but may be exercised where the offence overwhelmingly bears a civil, commercial, financial, matrimonial, or familial character and the victim and accused have amicably resolved the dispute.

The Court found that the dispute arose out of allegations relating to jointly owned land, disputed title documents, an agreement, possession documentation, and a connected civil suit, and therefore bore an essentially civil character.

The parties had executed a compromise, and its genuineness had been verified before the Principal Registrar.

Applying the principle in Gian Singh, the Court held that the settlement substantially removed the subsisting dispute between the parties and that continuation of the criminal case would serve no useful purpose.

Since the allegations did not fall within the category of grave offences for which private settlement cannot justify quashing, permitting the prosecution to continue would defeat the ends of justice.

It allowed the application under Section 528 of the BNSS, 2023 and quashed FIR/Crime No. 215/2024, registered at Police Station Rajendra Nagar, Indore, for offences under Sections 420, 447, 465 and 120-B of the IPC, together with all consequential proceedings pending against the applicants.

The petition was accordingly allowed and disposed of.