High Court may quash non-heinous criminal proceedings, including SC/ST Act charges, following a private settlement between parties.

The Petitioner filed a petition to quash the FIR and entire criminal proceedings in Barharwa P.S. Case No. 79 of 2025

The FIR alleged offenses under Sections 190, 191(2), 191(3), 126(2), 115(2), 118(1), 352, 351(2), and 109(2) of the Bharatiya Nyaya Sanhita (BNS), 2023, along with various provisions of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989

While the investigation was ongoing and no charge-sheet had been filed, the Petitioner and the Informant (Opposite Party No. 2) entered into a compromise with the assistance of well-wishers

Both parties filed affidavits stating that the dispute, which possessed a "civil flavour," had been resolved and the Informant no longer wished to proceed with the prosecution

Whether the High Court, in the exercise of its inherent powers under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, should quash criminal proceedings when the parties have reached a private settlement

Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which preserves the inherent power of the High Court to prevent the abuse of the process of any court or to secure the ends of justice

Parbatbhai Aahir @ Parbatbhai Bhimsinhbhai Karmur and Others v. State of Gujarat and Another (2017) 9 SCC 641

This precedent establishes that while heinous crimes like murder or rape cannot be quashed via settlement, cases involving private disputes, commercial transactions, or those with a "predominatingly civil flavour" may be quashed if the possibility of conviction is remote due to a compromise

The Court observed that the allegations did not constitute heinous offenses or crimes of "mental depravity" but rather stemmed from a private dispute

It noted that the Petitioner and the victim had reached a complete settlement, supported by mutual affidavits

The Court reasoned that because of this compromise, the likelihood of a successful conviction was "remote and bleak"

Therefore, allowing the criminal proceedings to continue would result in "great oppression and prejudice" to the Petitioner and would constitute an abuse of the process of law

The Court determined that quashing the proceedings was necessary to secure the ends of justice and prevent extreme injustice to the accused

The Court allowed the petition and quashed the entire criminal proceeding, including the FIR in Barharwa P.S. Case No. 79 of 2025, pending in the court of the learned Special Judge, SC/ST Act, Sahibganj, specifically regarding the Petitioner

Interlocutory Application No. 4652 of 2026 was disposed of accordingly