Non-compoundable criminal proceedings may be quashed where voluntary compromise makes trial futile.

The petitioner invoked Section 482 of the Code of Criminal Procedure, 1973 / Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, seeking quashing of FIR Crime No. 15/2026, registered at Police Station Bagchini, District Morena, for an offence under Section 137(2) of the Bharatiya Nyaya Sanhita, 2023, and consequential proceedings.

The petitioner and respondent No. 2, the complainant, stated that they had married, were living as husband and wife, and had settled their dispute.

Their compromise applications and affidavits were verified by the Principal Registrar, who reported that the compromise was voluntary and free from threat, inducement, or coercion.

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

Whether the FIR and consequential proceedings for an offence under Section 137(2) of the BNS could be quashed on the basis of the parties’ compromise.

Whether continuation of the criminal proceedings would serve any useful purpose in light of the verified, voluntary settlement.

The Court considered its inherent powers under Section 482 CrPC / Section 528 BNSS to prevent abuse of the process of law and secure the ends of justice.

Relying 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*, the Court stated that criminal proceedings may, in appropriate cases, be quashed on the basis of compromise even where the offence is non-compoundable.

The stated principle is that the Court may quash proceedings where, having regard to the settlement and circumstances, their continuation would be futile and quashing would prevent abuse of process.

The Court relied on the Registrar’s verification that the compromise was voluntary and on the parties’ stated marital relationship and desire to settle their dispute.

Although the State opposed the petition, the complainant supported the compromise.

Applying its stated approach to quashing on settlement, the Court concluded that continuing the proceedings would be a futile exercise and would serve no purpose.

It allowed the petition and quashed FIR Crime No. 15/2026, registered at Police Station Bagchini, District Morena, under Section 137(2) of the BNS, together with any consequential proceedings, on the basis of the compromise.