High Court may quash non-compoundable SC/ST Act offences on compromise in purely private disputes.

The petitioners challenged FIR No. 0015/2024 dated 25 March 2024, registered at Police Station Dharchula, District Pithoragarh, under Section 323 of the Indian Penal Code and Section 3(1)(x) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

They sought quashing of the FIR and protection from arrest.

During the proceedings, the petitioners and respondent nos. 3 and 4 appeared through video conferencing and were identified by their respective counsel.

The parties filed a compounding application, affidavits, and a compromise memo, stating that the settlement was voluntary and free from coercion.

Respondent no. 3, Naresh Singh, confirmed that the dispute had been settled and that he did not wish to prosecute the petitioners further.

The State raised no objection to the application, while acknowledging that offences under the SC/ST Act are non-compoundable.

1. Whether the High Court could quash the FIR involving a non-compoundable offence under the SC/ST Act where the parties had amicably settled a private dispute.

2. Whether, in view of the compromise and the complainant’s unwillingness to prosecute, continuation of the criminal proceedings would serve any useful purpose.

The Court exercised its jurisdiction under Article 226 of the Constitution of India to consider quashing of the criminal proceedings on the basis of a genuine settlement.

Although offences under the SC/ST (Prevention of Atrocities) Act are non-compoundable, the Court relied on Gian Singh v. State of Punjab, (2012) 10 SCC 303; Dimpey Gujral v. Union Territory, Chandigarh, (2013) 11 SCC 497; B.S. Joshi v. State of Haryana, (2003) 4 SCC 675; and Nikhil Merchant v. CBI, (2008) 9 SCC 677, for the principle that constitutional or inherent judicial powers may be exercised to terminate criminal proceedings in appropriate cases involving predominantly private disputes, where continuation of the prosecution would be futile and the ends of justice would be served by quashing.

The Court also considered the substantive allegations under Section 323 IPC and Section 3(1)(x) of the SC/ST Act.

The Court verified that the compromise was voluntary: the parties appeared before the Court, respondent no. 3 expressly stated that he no longer wished to prosecute, and the compromise was supported by affidavits and a written memo.

Although the SC/ST Act offence was non-compoundable, the Court characterised the underlying dispute as personal in nature and found that the parties had resolved it amicably.

Applying the principles in the cited Supreme Court decisions, the Court concluded that requiring the parties to undergo a criminal trial would be a futile exercise and that quashing the FIR would advance the ends of justice.

Criminal Writ Petition No. 1857 of 2026 was accordingly disposed of, and the compounding application and compromise memo were directed to form part of the order.