Inherent powers under Section 528 BNSS permit quashing non-compoundable personal disputes upon amicable settlement.

The Applicant approached the High Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, seeking to quash the charge-sheet dated 25.08.2025, the cognizance and summoning order dated 03.11.2025, and all proceedings in Criminal Case No. 593 of 2025

The Applicant was charged with offenses under Sections 109(1), 115(2), 333, 351(3), and 352 of the Bharatiya Nyaya Sanhita (B.N.S.), 2023

During the proceedings, the parties filed a joint Compounding Application (I.A. No. 01 of 2025), asserting that the dispute had been settled amicably

The Applicant and Respondent Nos. 2 and 3 appeared in person, were identified by counsel, and confirmed to the Court that they did not wish to pursue the matter further

1. Whether the criminal proceedings against the Applicant should be quashed in light of an amicable settlement between the parties, notwithstanding the non-compoundable nature of certain involved offenses

2. Whether the continuation of the criminal proceedings would amount to an abuse of the process of law

The Court exercised its inherent powers under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (the successor to Section 482 of the CrPC), which allows the High Court to issue orders necessary to prevent the abuse of the process of any court or to secure the ends of justice

The Court relied on the principle that in disputes of a purely personal nature, the High Court may quash proceedings if a settlement is reached and continuation would serve no useful purpose, even if the State opposes the prayer on the grounds of non-compoundable offenses

The Court conducted a personal interaction with the Applicant and Respondent Nos. 2 and 3, verifying that the settlement was voluntary and that the parties had no objection to the quashing of the proceedings

While the State Counsel argued against compounding due to the non-compoundable nature of some offenses [para. 8], the Court observed that the underlying dispute was "purely personal in nature"

The Court reasoned that since the parties had settled, the continuation of the trial would be a futile exercise and would ultimately "amount to an abuse of the process of law"

Consequently, the Court determined that the interest of justice favored the termination of the proceedings

The Court held that quashing was necessary to prevent the abuse of the process of law

The Criminal Miscellaneous Application filed under Section 528 of the BNSS was accordingly disposed of