Inherent jurisdiction permits quashing non-compoundable offences where disputes are private and compromise is genuine.

The applicant invoked Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (“BNSS”) seeking quashing of FIR Crime No. 471/2018 registered at Police Station Lordganj, Jabalpur, for offences under Sections 417, 419, 468 and 120-B of the Indian Penal Code, the chargesheet dated 14.02.2026, and consequential proceedings in RCT No. 1904/2026, subsequently numbered S.T. No. 195/2026.

The prosecution alleged that appointment letters were issued in the name of “SAPAKS” to Amit Khampariya and Deepak Pachori, who allegedly represented themselves as authorised office-bearers during the 2018 Madhya Pradesh Legislative Assembly elections.

The applicant contended that he was associated with “Samanya Pichhda Alpsankhyak Kalyan Samaj Society (SAPAKS Sanstha),” distinct from the SAPAKS political party, and that the dispute concerned internal organisational authority.

He also relied on the nearly eight-year delay between registration of the FIR and filing of the chargesheet, his age and medical condition, and the parties’ subsequent settlement.

Respondent No. 2 filed IA No. 15036/2026 under Sections 359 and 528 BNSS, confirming the compromise and expressing no objection to quashing the proceedings against the applicant.

The State opposed quashing in principle but accepted that appropriate orders could be passed if the compromise was genuine and the dispute was private in nature.

1. Whether the High Court should exercise its inherent jurisdiction under Section 528 BNSS to quash the FIR, chargesheet and consequential criminal proceedings against the applicant on the basis of a genuine compromise.

2. Whether the alleged offences under Sections 417, 419, 468 and 120-B IPC arose from a predominantly private and organisational dispute, such that continuation of the prosecution would amount to an abuse of the process of law.

3. Whether the unexplained delay of nearly eight years in completing the investigation and filing the chargesheet, together with the applicant’s age and medical condition, constituted relevant circumstances favouring quashing of the proceedings.

The Court applied Section 528 BNSS, which preserves the High Court’s inherent jurisdiction to prevent abuse of process and secure the ends of justice, and considered the compromise under Section 359 BNSS.

It examined the offences alleged under Sections 417, 419, 468 and 120-B IPC.

Relying on Gian Singh v. State of Punjab, (2012) 10 SCC 303, Narinder Singh v. State of Punjab, (2014) 6 SCC 466, and State of Madhya Pradesh v. Laxmi Narayan, (2019) 5 SCC 688, the Court reiterated that criminal proceedings may be quashed where the dispute has an overwhelmingly civil, private or personal character, the compromise is genuine, and continuation of the prosecution would constitute an abuse of process, subject to the limitation that serious, heinous or societally harmful offences ordinarily should not be quashed solely on the basis of compromise.

Delay in prosecution, though not independently determinative, may be considered while assessing whether continuation of the proceedings would serve the ends of justice.

The Court characterised the allegations as arising from the issuance of appointment letters and competing claims of representative authority within or concerning the SAPAKS organisation, rather than from offences of a heinous nature or offences affecting the State or society at large.

It found that the dispute was essentially private and organisational, and therefore fell within the category of matters in which inherent jurisdiction may be exercised following a genuine settlement.

Respondent No. 2 had expressly affirmed, by affidavit, that the compromise was voluntary and that she had no objection to quashing the proceedings; the Court found no material casting doubt on its genuineness.

The unexplained delay of approximately eight years in filing the chargesheet, the applicant’s age of 68 years, and his serious medical conditions were treated as additional circumstances supporting the conclusion that continuation of the prosecution would cause unnecessary harassment and would not advance any overriding public interest.

In light of the settlement and the remote possibility of conviction, continuation of the proceedings was held to constitute an abuse of the process of law.

FIR Crime No. 471/2018, Chargesheet No. 01/2026 dated 14.02.2026, and all consequential proceedings, including RCT No. 1904/2026, now S.T. No. 195/2026, were quashed qua the applicant Lalit Shastri only.