MP HC Quashes Cheating And Forgery FIR Against Woman After Complainant Confirms Voluntary Compromise

The petitioner sought to quash FIR Crime No. 440/2023, registered at the instance of respondent No. 2 for offences under Sections 420, 467, 468 and 471 of the IPC, and all consequential proceedings, relying on a compromise between the parties.

The compromise was verified by the concerned Registrar, who reported that it had been entered into voluntarily, without threat, inducement or coercion.

Respondent No. 2 consented to quashing, while the State opposed the petition.

Section 528 of the BNSS empowers the High Court to quash criminal proceedings to secure the ends of justice. Relying on Gian Singh v. State of Punjab, Narinder Singh v. State of Punjab, Ramavtar v. State of M.P., and other cited authorities, the Court noted that proceedings for non-compoundable offences may be quashed on compromise in appropriate cases.

Under State of Madhya Pradesh v. Laxmi Narayan, such power may be exercised where the dispute is predominantly private or civil in character and has been fully resolved, but ordinarily not for heinous or serious offences having a substantial societal impact.

Kapil Gupta v. State of NCT of Delhi further requires consideration of the sufficiency of evidence, the likelihood of conviction, the effect of settlement on the parties’ relationship, and the stage of proceedings.

The Court relied on the verified, voluntary compromise and respondent No. 2’s consent to quashing.

It found that the dispute was between the parties, that they had restored good relations, and that the prospect of conviction was remote in light of the compromise. Considering the cited principles and the potential for renewed discord if the dispute remained pending, the Court concluded that quashing was appropriate in the interests of justice.

The petition was disposed of accordingly.