Non-compoundable criminal proceedings quashed upon compromise where accused and victim have subsequently married.

The petitioner filed a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) seeking to quash FIR Crime No. 183/2019 registered at Police Station Noorabad, District Morena.

The charges involved Sections 376-D (gang rape) and 120-B (criminal conspiracy) of the IPC, alongside Sections 3(1)(w)(ii) and 3(2)(v) of the SC/ST Act.

During the proceedings, the petitioner and the complainant (Respondent No. 4) entered into a compromise and subsequently married each other.

Applications for compromise (I.A. No. 24559/2024 and I.A. No. 24560/2024) were filed, and the Principal Registrar verified that the settlement was reached voluntarily and without coercion.

Whether the High Court can exercise its inherent powers to quash criminal proceedings for non-compoundable offences, including rape and SC/ST Act violations, on the basis of a compromise when the parties have subsequently married.

The Court primarily exercised its inherent power under Section 528 of the BNSS (the successor to Section 482 of the CrPC) to prevent the abuse of the process of law.

It relied on the legal principle that even in non-compoundable cases, proceedings can be quashed if the settlement makes the chance of conviction remote and quashing would save judicial time.

This was supported by a catena of Supreme Court precedents, including Gian Singh v. State of Punjab (2012) regarding the quashing of non-compoundable offences, Narinder Singh v. State of Punjab (2014), and Parbatbhai Ahir v. State of Gujarat (2017).

The Court noted that the petitioner and Respondent No. 4 have married and settled their disputes peacefully.

It observed that the Principal Registrar had verified the intent and signatures of the parties, confirming the voluntary nature of the compromise.

Applying the cited precedents, the Court reasoned that since the parties are now husband and wife, the continuation of the criminal trial would be a "futile exercise" and a "wasteful exercise by the courts below" that would serve no material purpose.

The Court emphasized that a "Lean Compromise is better than a Fat Law Suit" and that quashing the proceedings was necessary to preserve the "bonhomie" and resources of the parties.

The High Court allowed the petition and quashed FIR Crime No. 183/2019 and all consequential proceedings arising therefrom.

The Court clarified that this order is specific to the settlement between the husband (petitioner) and wife (respondent No. 4) and shall not affect other cases.