High Court may quash non-compoundable SC/ST Act proceedings on settlement where allegations are not grave.

The petitioner, a KSRTC Traffic Controller, sought to quash proceedings in Spl.C.C. No. 31 of 2024 arising from Crime No. 354 of 2023, registered for offences under Sections 3(1)(r) and 3(1)(s) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, and Section 504 IPC.

The petitioner and respondent No. 2, the complainant and the petitioner’s colleague, reported that they had amicably settled their dispute and jointly sought quashing; both appeared before the Court and stated that the settlement was voluntary and free from coercion.

The State submitted that offences under the SC/ST (Prevention of Atrocities) Act are non-compoundable.

1. Whether the High Court could exercise its inherent jurisdiction under Section 482 Cr.P.C. to quash proceedings for non-compoundable offences under the SC/ST (Prevention of Atrocities) Act on the basis of a settlement between the parties.

2. Whether the nature of the allegations and the parties’ voluntary settlement justified quashing the proceedings in this case.

Section 320 Cr.P.C. governs compounding of offences, but the High Court’s inherent power under Section 482 Cr.P.C. may extend to quashing proceedings for non-compoundable offences where warranted by the nature and gravity of the allegations and the circumstances of the settlement.

Relying on Ramgopal v. State of Madhya Pradesh, (2022) 14 SCC 531, the Court stated that this power may be exercised notwithstanding the limitations in Section 320 Cr.P.C.

The proceedings involved alleged offences under Sections 3(1)(r) and 3(1)(s) of the SC/ST (Prevention of Atrocities) Act and Section 504 IPC.

Although the State correctly noted that the SC/ST Act offences were non-compoundable, the Court treated compounding under Section 320 and quashing under Section 482 as distinct.

The parties were colleagues, had settled the dispute, and confirmed that their settlement was voluntary and free from undue influence or coercion.

Finding that the allegations in the complaint and charge sheet were not grave, the Court considered the case appropriate for exercise of its inherent power.

It quashed, as against the petitioner, the entire proceedings in Spl.C.C. No. 31 of 2024 arising from Crime No. 354 of 2023 for the alleged offences under Sections 3(1)(r) and 3(1)(s) of the SC/ST (Prevention of Atrocities) Act and Section 504 IPC.