High Courts may quash non-compoundable proceedings, including SC/ST Act charges, after settlement where conviction is remote.

The petitioners, accused Nos. 1–6, sought to quash the proceedings arising from Sankeshwar Police Station Crime No. 92/2025, registered on the complainant’s 20 May 2025 complaint.

The charge-sheet invoked Sections 115(2), 126(2), 189(2), 190, 352, 191(2) and 117(2) of the Bharatiya Nyaya Sanhita, 2023, and Sections 3(1)(r), 3(1)(s) and 3(2)(va) of the SC/ST (Prevention of Atrocities) Act.

The parties later settled their dispute with the assistance of elders; the complainant and the victim filed affidavits stating that the settlement was voluntary and that they had no objection to quashing.

The judgment’s final order identifies the pending case as Special Case No. 520/2025, although the compromise application and affidavits refer to Special Case No. 504/2025.

1. Whether the High Court should exercise its inherent jurisdiction to quash proceedings for non-compoundable offences on the basis of a voluntary settlement between the parties.

2. Whether, on the facts and material before it, continuation of the proceedings would serve a useful purpose given the settlement and the Court’s assessment that the prospect of conviction was remote.

The Court considered Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (corresponding to Section 482 of the Code of Criminal Procedure) as the source of the High Court’s inherent power to quash proceedings, distinct from the statutory power to compound offences under Section 359 BNSS/Section 320 CrPC.

Relying on Narinder Singh v. State of Punjab, (2014) 6 SCC 466, particularly paragraphs 31–35 of that decision, the Court applied the principles that quashing on settlement is discretionary, must serve the ends of justice or prevent abuse of process, and requires consideration of the nature of the offence, the circumstances of settlement, and the likelihood of conviction.

The Court also referred to a coordinate Bench decision in Criminal Petition No. 102688/2025.

The Court accepted the complainant’s and victim’s affidavits as confirming a voluntary settlement reached with the assistance of family and village elders.

It characterized the dispute as a private disagreement between relatives and observed that the accused persons’ individual roles and direct nexus to the alleged offences were not clearly established in the complaint.

In light of the settlement, it considered that the witnesses were unlikely to support the prosecution and that the chances of conviction were remote; continuing the proceedings would therefore be unnecessary.

Applying the inherent-power principles in Narinder Singh, the Court concluded that quashing would serve the interests of justice.

Pending applications were disposed of as not surviving for consideration.