Non-compoundable criminal proceedings may be quashed under inherent powers when private disputes are amicably settled.

The applicants filed a C-528 application (under Section 528 of the BNSS/482 Cr.P.C.) seeking to quash the charge-sheet and proceedings of Criminal Case No. 4713 of 2019.

The case originated from an F.I.R. alleging offences under Sections 420 (cheating) and 406 (criminal breach of trust) of the I.P.C., and Sections 4/5 of the Prize Chits & Money Circulation Scheme (Banning) Act, 1978.

During the pendency of the trial before the Chief Judicial Magistrate, Dehradun, the parties arrived at an amicable settlement with the help of respectable society members.

The applicants paid a total of ₹4,00,000 to Respondent No. 2 (complaint)—comprising ₹1,00,000 previously paid in cash and ₹3,00,000 via a demand draft delivered in open court.

1. Whether the High Court can exercise its inherent jurisdiction to quash criminal proceedings involving non-compoundable offences on the basis of a private settlement between parties.

2. Whether the continuation of proceedings in Case No. 4713 of 2019 would constitute an abuse of the process of law given the amicable resolution.

Section 528 of the Bhartiya Nagarik Suraksha Sanhita (BNSS) (formerly Section 482 of the Cr.P.C.) regarding the inherent powers of the High Court to prevent abuse of the process of law.

Landmark precedents of Gian Singh v. State of Punjab, Narinder Singh v. State of Punjab, and Parbatbhai Aahir v. State of Gujarat, which established that proceedings involving offences of a personal or private nature can be quashed even if the offences are non-compoundable, provided the ends of justice are served and the settlement is voluntary.

The court observed that the dispute between the parties was essentially private in nature, arising from a personal discord.

Upon interacting with the parties—specifically Respondent No. 2 via Video Conferencing—the court verified that the refund of the entire alleged amount was completed and the compromise was entered into voluntarily without coercion.

The court applied the "personal nature" test from Gian Singh to determine that because the victim no longer wished to prosecute and a settlement had been reached, the likelihood of conviction was remote.

The court reasoned that forcing the continuation of the trial would be a futile exercise and a waste of judicial time.

The Court allowed Compounding Application (I.A. No. 1 of 2026) and the main C-528 application; consequently, the charge-sheet, the summoning order dated 09.09.2019, and the entire proceedings of Criminal Case No. 4713 of 2019 pending before the CJM, Dehradun, were quashed.