High Courts may quash non-heinous criminal proceedings after amicable settlement where conviction is remote.

The petitioner sought to quash the FIR and criminal proceedings in Jainagar P.S. Case No. 87 of 2022, registered under Sections 354A, 469 and 506 of the Indian Penal Code and Sections 66C, 66E and 67 of the Information Technology Act. At the time of the petition, the investigation was ongoing and no charge-sheet had been filed against him.

During the proceedings, the petitioner and Opposite Party No. 2 informed the Court that they had amicably settled their dispute, which arose from a misunderstanding, and that Opposite Party No. 2 did not wish to proceed with the case. The State did not oppose the request for quashing.

Whether the High Court should exercise its inherent jurisdiction under Section 482 of the Code of Criminal Procedure to quash the FIR and criminal proceedings in light of the parties’ settlement?

Whether the nature of the alleged offences and the circumstances of the settlement made continuation of the proceedings an abuse of process or contrary to the ends of justice?

Section 482 of the Code of Criminal Procedure preserves the High Court’s inherent power to prevent abuse of the process of any court or otherwise secure the ends of justice.

Relying on Parbatbhai Aahir @ Parbatbhai Bhimsinhbhai Karmur v. State of Gujarat, (2017) 9 SCC 641, which set out the principles in Gian Singh v. State of Punjab, (2012) 10 SCC 303, the Court noted that this power is distinct from statutory compounding under Section 320 CrPC. A settlement may justify quashing where the dispute is essentially private or personal, the offences are not heinous or of serious mental depravity, the prospect of conviction is remote, and continuation would cause oppression or prejudice; the Court must consider the nature and gravity of the offence and the interests of justice.

The Court treated the case as arising from a misunderstanding between the parties and noted that they had reached a final settlement, with Opposite Party No. 2 unwilling to pursue the matter.

It found that the offences were neither heinous nor offences involving serious mental depravity, and that continuation of the proceedings would cause hardship to the petitioner. Applying the principles governing Section 482 CrPC, the Court considered the settlement and the nature of the alleged offences sufficient to warrant quashing.

The criminal miscellaneous petition was allowed, and Interlocutory Application No. 14268 of 2026 was disposed of accordingly.