Non-compoundable criminal proceedings may be quashed after settlement where conviction is remote.

Respondent No. 2 alleged that on 23 April 2024, the petitioners wrongfully restrained and abused him, assaulted him on the head with an iron rod, causing bleeding injuries, and threatened him.

Shirahatti Police registered Crime No. 65/2024; after investigation, a charge sheet was filed for offences under Sections 341, 324, 504 and 506 read with Section 34 of the IPC, and proceedings were pending in C.C. No. 810/2024 before the JMFC, Laxmeshwar, sitting at Shirahatti.

The parties, who were residents of the same village, later settled their dispute with the intervention of village elders and jointly sought compounding and quashing of the proceedings.

1. Whether the High Court should exercise its inherent jurisdiction to quash proceedings for non-compoundable offences under Sections 341, 324, 504 and 506 read with Section 34 IPC, in view of the parties’ settlement.

2. Whether the settlement and circumstances of the case made the likelihood of conviction sufficiently remote that continuing the prosecution would amount to an unnecessary continuation of proceedings.

Section 320 CrPC governs the compounding of specified offences; the High Court’s inherent power under Section 482 CrPC (also referred to in the petition under Section 528 BNSS) is distinct and may be exercised to quash proceedings for non-compoundable offences where doing so serves the ends of justice or prevents abuse of the process of court.

Relying on Narinder Singh v. State of Punjab, (2014) 6 SCC 466, particularly paragraphs 31–35, the Court applied the principles that settlement may support quashing in appropriate cases, but the Court must consider the nature and seriousness of the offence, the circumstances and timing of settlement, and whether the prospect of conviction is remote; this power is not ordinarily to be used for heinous offences or offences having a serious societal impact.

The Court considered the allegations, the charge-sheet material, and the parties’ joint compromise application and affidavits.

It found that the dispute had been settled voluntarily, with the intervention of village elders, between parties living in the same village.

Given the settlement, the Court considered the prospect of witnesses supporting the prosecution to be minimal and the likelihood of conviction remote.

It therefore concluded that continuing the prosecution would be unnecessary and that quashing would serve the interests of justice.

It quashed the proceedings in C.C. No. 810/2024 arising from Crime No. 65/2024, insofar as they concerned petitioners/accused Nos. 1–4, for offences under Sections 341, 324, 504 and 506 read with Section 34 IPC.

I.A. No. 1 of 2026 was also allowed.