High Courts may quash non-heinous criminal proceedings arising from private disputes upon settlement.

The petitioner sought to quash the criminal proceedings in Lohsingha P.S. Case No. 37 of 2025, corresponding to G.R. No. 2252 of 2026, including the order dated 17 August 2026 taking cognizance of offences under Sections 191(2), 191(3), 126(2), 115(2), 118(1) and 351(2) of the Bharatiya Nyaya Sanhita, 2023

The petitioner and the informant-victim filed affidavits stating that they had settled their personal dispute and that the informant did not wish to proceed. The State had no objection to quashing

Whether the High Court should exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 to quash the criminal proceedings on the basis of the parties’ compromise

Whether, in light of the settlement and the nature of the alleged offences, continuation of the proceedings would be contrary to the interests of justice

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 preserves the High Court’s inherent power to prevent abuse of process and secure the ends of justice

In Parbatbhai Aahir @ Parbatbhai Bhimsinhbhai Karmur v. State of Gujarat, (2017) 9 SCC 641, relying on Gian Singh v. State of Punjab, (2012) 10 SCC 303, the Supreme Court held that the High Court may quash proceedings following a settlement where the dispute is predominantly private or personal, the possibility of conviction is remote, and continuation would cause injustice; heinous or serious offences with a substantial societal impact ordinarily cannot be quashed merely on compromise

The Court found that the offences involved were neither heinous nor offences involving serious mental depravity, and that the case arose from a misunderstanding between the parties that had been amicably resolved

In view of the settlement, the informant’s unwillingness to proceed, and the consequent remote prospect of conviction, the Court considered that continuing the case would cause hardship to the petitioner and justified quashing under its inherent jurisdiction

It quashed and set aside, qua the petitioner, the entire criminal proceeding in Lohsingha P.S. Case No. 37 of 2025, corresponding to G.R. No. 2252 of 2026, including the cognizance order dated 17 August 2026. The connected interlocutory application was disposed of