High Court quashes SC/ST Act proceedings upon compromise, directing refund of state-paid victim compensation.

The petitioners filed a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) seeking the quashment of FIR Crime No. 611/2023 registered at Police Station Chachoda, District Guna

The charges included Section 420 (cheating) and 34 (common intention) of the Indian Penal Code (IPC), alongside Section 3(2)(V-a) of the SC/ST (Prevention of Atrocities) Act

During the proceedings, the parties filed interlocutory applications (I.A. Nos. 3431/2026 and 3565/2026) stating that their dispute had been resolved through a voluntary compromise

The Principal Registrar of the High Court verified the factum of the compromise, confirming that the statements were recorded without threat, inducement, or coercion

1. Whether the High Court can exercise its inherent powers to quash criminal proceedings involving non-compoundable offences on the basis of a settlement between the parties.

2. Whether the continuation of prosecution in a matter predominantly civil or personal in nature, where a compromise has been reached, constitutes an abuse of the process of law.

Section 528 of the BNSS (equivalent to Section 482 of the Cr.P.C.) regarding the inherent powers of the High Court

The Court relied on the principle established in Gian Singh v. State of Punjab (2012), which distinguishes between the compounding of offences under Section 320 Cr.P.C. and the quashing of proceedings to secure the ends of justice

State of M.P. v. Laxmi Narayan (2019), which allow quashing of non-compoundable offences that have a "predominantly civil character" or arise from commercial/matrimonial disputes, provided they do not involve heinous crimes like murder or rape

K. Bharthi Devi v. State of Telangana (2024) to affirm that the High Court is justified in quashing proceedings even if offences are non-compoundable, provided the victim and offender have settled amicably

The Court reasoned that the inherent power under Section 528 of the BNSS is wide and intended to prevent the abuse of the legal process

By examining the nature of the dispute, the Court determined that the matter involved issues that could be resolved through private settlement

Following the precedents of Gian Singh and Narinder Singh, the Court observed that while the offences charged were technically non-compoundable, the voluntary settlement reached by the parties rendered further prosecution a "futile exercise" that would serve no societal purpose and waste judicial time

The Court emphasized that when a wrong is essentially private or personal and the parties have resolved the entire dispute, the High Court’s intervention is necessary to prevent "wasteful exercise by the courts below"

The High Court allowed the petition and directed that FIR Crime No. 611/2023 and all consequential proceedings be quashed

the Court ordered the complainant to return any compensation received under the provisions of the SC/ST Act in accordance with applicable rules

The petition was disposed of with no order as to costs