Non-compoundable matrimonial proceedings may be quashed under Section 482 CrPC on voluntary compromise.

The petitioners invoked Section 482 Cr.P.C./Section 528 BNSS seeking quashing of FIR Crime No. 01/2021, registered at Mahila Thana, Gwalior, for offences under Sections 498-A, 506 and 34 IPC and Section 4 of the Dowry Prohibition Act, 1961, together with consequential proceedings.

The parties filed compromise applications supported by affidavits. The Principal Registrar verified the parties, signatures, contents and voluntariness of the compromise, finding no threat, inducement or coercion.

The complainant supported the petition; the State opposed it.

1. Whether the High Court could quash the FIR and consequential proceedings for non-compoundable offences on the basis of the parties’ compromise?

2. Whether the verified compromise in this case justified exercising that power to prevent a futile continuation of the criminal proceedings?

The Court considered the High Court’s inherent jurisdiction under Section 482 Cr.P.C. (and Section 528 BNSS) to prevent abuse of process and secure the ends of justice.

Relying on Jagdish Channa v. State of Haryana, AIR 2008 SC 1968; Madan Mohan Abbot v. State of Punjab, AIR 2008 SC 1969; Shiji v. Radhika, (2011) 10 SCC 705; Narinder Singh v. State of Punjab, (2014) 6 SCC 466; B.S. Joshi v. State of Haryana, (2003) 4 SCC 675; Gian Singh v. State of Punjab, (2012) 10 SCC 303; and Parbatbhai Ahir v. State of Gujarat, (2017) 9 SCC 641, the Court stated that criminal proceedings may, in appropriate cases, be quashed on the basis of compromise even where the offences are non-compoundable.

The Court accepted the Registrar’s verification that the compromise was voluntary and free from coercion.

The complainant supported settlement, and the Court concluded that continuation of the trial would be futile and serve no useful purpose.

Applying its inherent powers and the cited compromise-quashing principles, it held that quashing would prevent a wasteful exercise by the courts below.