High Court Quashes Non-Compoundable Section 304A IPC Proceedings Following MACT Settlement and Party Compromise

The applicant, Rajdeep Gogoi, was facing trial in Criminal Case No. 5886 of 2024 for offences under Sections 279 (rash driving) and 304A (causing death by negligence) of the IPC.

The incident stemmed from a vehicular accident resulting in the death of the respondent/complainant’s husband during treatment.

Subsequent to the incident, the Motor Accident Claims Tribunal (MACT) awarded compensation to the respondent.

Consequently, the parties settled the dispute and filed a compounding application under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, seeking to quash the proceedings based on this settlement.

1. Whether the High Court can exercise its inherent power to quash criminal proceedings for non-compoundable offences under the IPC based on a private settlement between parties.

2. Whether the settlement in a case involving Section 304A IPC, where MACT compensation has already been awarded, fulfills the criteria for quashing proceedings to secure the ends of justice.

The court applied Section 528 of the BNSS, 2023 (formerly Section 482 CrPC), which grants the High Court inherent powers to quash proceedings to prevent abuse of process or secure the ends of justice.

It relied heavily on the precedent Narinder Singh and Ors. v. State of Punjab (2014) 6 SCC 466, which established that while the High Court must exercise caution in non-compoundable cases, it may quash proceedings if the possibility of conviction is remote, the dispute is predominantly civil/private in nature, or if settlement promotes harmony.

The court also noted that while Sections 279 and 304A IPC are technically non-compoundable under Section 320 CrPC, they can be compounded with the leave of the court under inherent powers.

The court observed that the incident was fundamentally an accident rather than a premeditated crime.

It noted that the MACT had already adjudicated the matter of compensation, which the complainant had accepted, signaling a resolution of the underlying grievance.

By applying the Narinder Singh framework, the Court determined that since the parties had reached a voluntary settlement and the complainant no longer wished to prosecute, the "ends of justice" would be better served by closing the case rather than continuing a trial where the chances of conviction were bleak and the proceedings would cause undue prejudice to the applicant.

The presence and identification of both parties in court further verified the authenticity of the compromise.

The Court allowed Compounding Application No. 2 of 2026 and the main application under Section 528 BNSS. Consequently, the entire proceedings of Criminal Case No. 5886 of 2024 (State vs. Rajdeep Gogoi) pending before the C.J.M. Dehradun were quashed.