High Court may quash SC/ST Act proceedings on genuine compromise where the dispute is private and complainant consents.

FIR No. 656/2023 dated 2 December 2023 was registered at Police Station Prem Nagar, District Rohini, Delhi, under Section 506 of the Indian Penal Code and Section 3(1)(r)(s) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Amendment Act, 2015.

The allegations were that the petitioners physically assaulted Respondent No. 2, used caste-based insults against him, and threatened to kill him.

A charge-sheet had been filed, and the matter was pending before the Additional Sessions Judge, Rohini Courts, for framing of charges.

During the proceedings, the parties entered into a written Settlement Agreement dated 30 July 2026, pursuant to which Respondent No. 2 agreed to support quashing of the criminal proceedings.

The parties appeared personally before the High Court and were identified by their respective counsel and the Investigating Officer. Respondent No. 2 confirmed that the settlement was voluntary and that he had no objection to quashing of the FIR.

Whether the High Court could exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, to quash the FIR and consequential proceedings on the basis of a settlement between the parties?

Whether the criminal proceedings arising from allegations under Section 506 IPC and Section 3(1)(r)(s) of the SC/ST Act should be quashed where the complainant had amicably settled the dispute and had no objection to quashing?

The Court applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which preserves the High Court’s inherent powers to make orders necessary to give effect to any order under the BNSS, prevent abuse of the process of court, or otherwise secure the ends of justice.

The Court also considered the offences alleged under Section 506 IPC and Section 3(1)(r)(s) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Amendment Act, 2015.

The governing principle applied was that criminal proceedings may be quashed in appropriate cases where the dispute is essentially private in nature, the parties have voluntarily settled their differences, the complainant does not wish to pursue the matter, and continuation of the proceedings would serve no useful purpose or involve any overriding public interest.

The Court found that the parties had voluntarily resolved their dispute through a written settlement and that Respondent No. 2 had expressly confirmed the settlement before the Court without force, fear, or coercion.

Although the allegations included caste-based insults and criminal intimidation, the Court treated the dispute, in the circumstances of the case, as primarily private and not involving a continuing public-interest concern.

Since the complainant no longer wished to press the allegations, the Court concluded that continuation of the prosecution would serve no useful purpose.

Exercising its inherent jurisdiction under Section 528 BNSS, the Court held that quashing the proceedings was necessary to secure the ends of justice.

The petition was allowed and disposed of.

The parties’ original affidavits were directed to be submitted before the Trial Court and to the concerned SHO/Investigating Officer within four weeks so that they could form part of the relevant records.