Uttarakhand High Court
Criminal Procedure and EvidenceCriminal Law

High Courts may quash non-compoundable criminal proceedings where settlement makes conviction remote.

DHEERAJ RAWAT AND ORS vs STATE OF UTTARAKHAND

Uttarakhand High CourtJUDGMENT: October 15, 20261 MIN READSOURCE JUDGMENT
High Courts may quash non-compoundable criminal proceedings where settlement makes conviction remote.. DHEERAJ RAWAT AND ORS vs STATE OF UTTARAKHAND. Uttarakhand High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The case arose from cross-FIRs following an altercation between the applicants and the complainant/respondents during Holi on 14 March 2025.

Source reference: para. 4–10

The parties lived in the same locality and later settled their dispute.

Source reference: para. 4–10

The applicants sought to set aside the chargesheet, cognizance/summoning order, and proceedings in Criminal Case No. 234 of 2026, pending before the Judicial Magistrate, Rishikesh.

Source reference: para. 4–10

The parties appeared before the High Court, filed affidavits recording the compromise, and confirmed during the Court’s interaction that the complainants did not wish to pursue the proceedings.

Source reference: para. 4–10
02

Issues

1. Whether the criminal proceedings could be quashed in light of the parties’ compromise, although the offences were stated to be non-compoundable

Source reference: para. 11–14

2. Whether the compromise between the parties justified quashing the proceedings against the applicants

Source reference: para. 8–10, 13–14
03

Law Applied

The Court relied on B.S. Joshi and Others v. State of Haryana, (2003) 4 SCC 675, and the principle it attributed to that decision that the High Court may permit resolution of non-compoundable offences in appropriate cases.

Source reference: para. 12

It also invoked the broader principle that criminal proceedings may be quashed where a settlement makes conviction remote and continuation of the proceedings would cause prejudice or injustice to the accused.

Source reference: para. 13
04

Reasoning

The Court considered the parties’ affidavits and their statements during its interaction, which confirmed that the dispute had been amicably resolved and the complainants did not wish to continue the prosecution.

Source reference: para. 8–10

Although the State objected that the offences were non-compoundable, the Court applied the compromise-based quashing principles it drew from B.S. Joshi and subsequent Supreme Court decisions.

Source reference: para. 11–13

It concluded that the settlement warranted ending the proceedings, without setting out a separate, offence-specific assessment.

Source reference: para. 14
05

Holding

The High Court allowed the compounding application and quashed the proceedings in Criminal Case No. 234 of 2026, pending before the Judicial Magistrate, Rishikesh, qua the applicants.

The criminal miscellaneous application was disposed of accordingly.

Source reference: para. 14–15
Uttarakhand High Court

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DHEERAJ RAWAT AND ORSvsSTATE OF UTTARAKHAND

Uttarakhand High Court · October 15, 2026

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