Madhya Pradesh High CourtCriminal LawCriminal Procedure and Evidence

MP HC Quashes 2012 Cheating-And-Forgery FIR Against Ravindra Prasad Pandey After Complainants’ Voluntary Compromise

Ravindra Prasad Pandeyv.The State Of Madhya Pradesh

MP HC Quashes 2012 Cheating-And-Forgery FIR Against Ravindra Prasad Pandey After Complainants’ Voluntary Compromise. Ravindra Prasad Pandey vs The State Of Madhya Pradesh. Madhya Pradesh High Court. LawLens
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In brief

The question

Whether the FIR and consequential proceedings for the alleged non-compoundable IPC offences could be quashed on the basis of the parties’ compromise.

The court held

The Court allowed the petition and quashed Crime No. 526/2012 and the consequential proceedings in S.T. No. 150/2021, insofar as they concerned Ravindra Prasad Pandey, on the basis of the compromise.

01Facts

The petitioner sought quashing under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, of Crime No. 526/2012 registered at Police Station Bahodapur, Gwalior, for offences under Sections 406, 420, 467, 468, 471 and 419 of the Indian Penal Code, together with the consequential proceedings in S.T. No. 150/2021.

¶ 1

The petitioner and respondent-complainants sought to resolve the dispute by compromise. Their applications and affidavits were verified by the Principal Registrar, who reported that the compromise was voluntary and free from threat, inducement or coercion.

¶ 2–3

The State opposed the petition, while the complainants supported it.

¶ 5–6

The Court also noted that proceedings concerning two co-accused had previously been quashed.

¶ 11

02Issues

i.Whether the FIR and consequential proceedings for the alleged non-compoundable IPC offences could be quashed on the basis of the parties’ compromise.

¶ 1, 9–10

ii.Whether the compromise was voluntary and sufficient, in the circumstances, to justify quashing the proceedings against the petitioner.

¶ 2–3, 10–13

03Law Applied

The Court relied on the High Court’s inherent jurisdiction, referring to Section 528 of the BNSS in the petition’s description and to Section 482 of the Code of Criminal Procedure in its reasoning, to prevent abuse of process and secure the ends of justice.

¶ 1, 10

It applied the principle that criminal proceedings for non-compoundable offences may, in appropriate cases, be quashed on compromise where continuation would serve no useful purpose.

¶ 9

In support, it cited Jagdish Channa v. State of Haryana, Madan Mohan Abbot v. State of Punjab, Shiji v. Radhika, Narinder Singh v. State of Punjab, B.S. Joshi v. State of Haryana, Gian Singh v. State of Punjab and Parbatbhai Ahir v. State of Gujarat.

¶ 9

Provisions in the judgment · 8 · Linked ones open on LawLens

Bharatiya Nagarik Suraksha Sanhita, 2023 Section 528

Indian Penal Code, 1860 Section 406Section 420Section 467Section 468Section 471Section 419

Code of Criminal Procedure, 1973 Section 482

04Reasoning

The Court accepted the Registrar’s verification that the parties had entered into the compromise voluntarily and noted that the complainants supported the petitioner’s request.

¶ 3–6

Applying the cited authorities, it concluded that continuation of the trial would be a futile exercise and would serve no purpose.

¶ 10

It also noted the prior quashing of proceedings against two co-accused.

¶ 11

On that basis, it allowed the compromise applications and quashed the proceedings against the petitioner.

¶ 12–13

05Holding

The Court allowed the petition and quashed Crime No. 526/2012 and the consequential proceedings in S.T. No. 150/2021, insofar as they concerned Ravindra Prasad Pandey, on the basis of the compromise.

¶ 12–14
Madhya Pradesh High Court

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Ravindra Prasad PandeyvsThe State Of Madhya Pradesh

Madhya Pradesh High Court · October 22, 2026

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