Non-compoundable offences arising from settled family disputes may be quashed under inherent powers.

In CRL.M.C. 6042/2026, the petitioners sought quashing of FIR No. 632/2018, registered under Sections 354/451/506/509/34 IPC, and the proceedings arising from it.

The Trial Court had found a prima facie case under Sections 506/509/34 IPC against all petitioners and under Section 354 IPC against petitioner no. 1.

In CRL.M.C. 6044/2026, the petitioners sought quashing of FIR No. 550/2018, registered under Sections 354/354A/34 IPC; the chargesheet included Sections 354/354A/323/34 IPC against Pawan Kumar Sahnan and Sections 323/34 IPC against the petitioners.

The parties belonged to the same extended family and had entered into a non-monetary MoU dated 6 May 2026 to resolve their disputes, including the two FIRs.

The MoU expressly excluded a separate POCSO-related FIR and complaint case; the Investigating Officer confirmed that the FIRs under consideration were unconnected with those excluded matters.

The parties stated that the settlement was voluntary and that they had no objection to quashing. The State raised no serious objection; the person against whom the primary allegations in FIR No. 550/2018 were made had died.

1. Whether the High Court should exercise its inherent jurisdiction to quash the two FIRs and consequential proceedings for non-compoundable offences on the basis of the parties’ settlement of their inter se family disputes.

2. Whether quashing the two FIRs would affect the separate POCSO-related proceedings expressly excluded from the MoU.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, corresponding to Section 482 of the Code of Criminal Procedure, 1973, preserves the High Court’s inherent power to quash criminal proceedings, distinct from the statutory power to compound offences.

Under Gian Singh v. State of Punjab, (2012) 10 SCC 303, Narinder Singh v. State of Punjab, (2014) 6 SCC 466, and State of Madhya Pradesh v. Laxmi Narayan, (2019) 5 SCC 688, that power may extend to non-compoundable offences where the dispute is predominantly civil or private, the parties have genuinely settled it, the prospect of conviction is remote and bleak, and continuation would cause oppression or would not serve the ends of justice.

Heinous or serious offences affecting society at large ordinarily should not be quashed merely because the parties have settled.

The Court treated the FIRs as arising from settled, inter se family disputes and accepted the parties’ representations that the MoU was voluntary and that they did not oppose quashing.

It considered that the POCSO-related FIR and complaint were expressly excluded from the settlement and, on the Investigating Officer’s confirmation, were unconnected with the two FIRs before it; quashing therefore would not compromise their adjudication.

In those circumstances, and with no serious objection from the State, the Court found no impediment to granting the joint request.

The petitions and pending applications were disposed of accordingly.