High Courts may quash non-compoundable SC/ST Act convictions under inherent powers following a voluntary post-conviction settlement.

The appellant was convicted by the Special Judge under the SC/ST (Prevention of Atrocities) Act, Seoni, on September 20, 2024, in SC ATR No. 67/2017.

He was sentenced to six months of Rigorous Imprisonment and a fine of Rs. 500 for each offence under Section 323 of the Indian Penal Code (IPC) and Sections 3(2)(va) and 3(1)(s) of the SC/ST (Prevention of Atrocities) Act.

During the pendency of the appeal, the parties entered into an amicable settlement and filed I.A. No. 20809 of 2025 seeking permission to compound the offences.

The Registrar Judicial-II verified the compromise on February 6, 2026, reporting that the complainant and the injured party had entered into the settlement voluntarily, without any threat or inducement.

Whether the High Court, in exercise of its inherent powers under Section 482 of the Cr.P.C., can quash convictions and compound offences under the SC/ST (Prevention of Atrocities) Act—which are otherwise non-compoundable—on the basis of a private settlement between the parties.

The Court primarily relied on the Supreme Court’s decision in Ramawatar v. State of Madhya Pradesh (2022), which established that the High Court may exercise its inherent powers under Section 482 of the Cr.P.C. to quash proceedings in non-heinous, private disputes even if they fall under "special statutes" like the SC/ST Act, provided the settlement is voluntary and the Act's underlying objective is not contravened.

It further applied the principles from Gian Singh v. State of Punjab (2012), which distinguishes the quashing of criminal proceedings under inherent jurisdiction from the statutory compounding of offences under Section 320 of the Cr.P.C., emphasizing that quashing is permissible to secure the ends of justice.

The Court analyzed the voluntary nature of the compromise, noting that the Registrar Judicial-II had formally verified the statements of the parties and confirmed the absence of coercion.

Although the offences under Sections 3(2)(va) and 3(1)(s) of the SC/ST Act are not compoundable under Section 320 Cr.P.C., the Court reasoned that the dispute was primarily private in nature and that continuing legal proceedings would constitute an abuse of the process of law.

By applying the guidelines from Ramawatar, the Court determined that the underlying objective of the SC/ST Act would not be diminished by allowing the compromise, as the settlement was struck with free will and the felony did not impact the broader conscience of society.

The Court held that there were no grounds to refuse the exercise of inherent powers under Section 482 of the Cr.P.C. to quash the charges.

Consequently, the judgment of conviction and order of sentence dated September 20, 2024, were set aside, and the appellant was acquitted of all charges under Section 323 IPC and Sections 3(2)(va) and 3(1)(s) of the SC/ST Act.

The appellant’s bail bonds and surety bonds were ordered to be discharged.