Non-compoundable criminal proceedings may be quashed on voluntary compromise where continuation serves no purpose.

The petitioner sought to quash FIR Crime No. 472/2025, registered at Police Station Khaniyadhana, District Shivpuri, for offences under Sections 308(1), 74, 331(3), 351(3) and 296(a) of the Bharatiya Nyaya Sanhita, 2023, and the consequential proceedings in S.T. No. 12/2026, on the basis of a compromise with respondent No. 2/complainant.

The parties filed compromise applications supported by affidavits.

The Principal Registrar verified their identities, signatures, and the voluntary nature of the settlement.

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

Whether the FIR and consequential proceedings could be quashed against the petitioner on the basis of the parties’ compromise, despite the offences being treated as non-compoundable.

Whether the relief should be confined to the petitioner, leaving the proceedings against the remaining co-accused unaffected.

The petition was brought under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023; in discussing the Court’s power, the judgment also referred to Section 482 of the Code of Criminal Procedure.

The Court relied on 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 for the principle that, in appropriate non-compoundable cases, criminal proceedings may be quashed on the basis of a compromise to prevent abuse of process and where continuation would serve no useful purpose.

The Court accepted the verified compromise as voluntary and supported by the parties’ affidavits.

Although the State opposed the petition, the complainant supported settlement. Applying the cited authorities, the Court concluded that continuing the proceedings against the petitioner would be a futile exercise and would serve no purpose.

FIR Crime No. 472/2025 and the consequential proceedings in S.T. No. 12/2026 were quashed only as against Mohit Parihar, on the basis of compromise.

The Court directed that the trial against the remaining co-accused proceed independently.

The trial against the remaining co-accused was to continue and be decided in accordance with law, uninfluenced by the order.