Non-compoundable proceedings may be quashed after settlement of a personal dispute when conviction is remote.

The petitioners, Accused Nos. 1–8, sought to quash proceedings in C.C. No. 743/2026 before the II JMFC, Belagavi, arising from Crime No. 233/2024 of Malmaruti Police Station.

The prosecution concerned alleged offences under Sections 189(2), 191(2), 115(2), 126(2), 74, 352, 351(2) and 190 of the Bharatiya Nyaya Sanhita, 2023

During the petition, the petitioners and the de facto complainant filed a joint application and affidavits stating that they had amicably settled the dispute voluntarily and without coercion

The State and the complainant’s counsel did not oppose quashing on the basis of the settlement

Whether the High Court could quash the criminal proceedings for the alleged non-compoundable offences under its inherent jurisdiction, notwithstanding the settlement between the parties

Whether, in the circumstances of the case, continuing the prosecution would amount to an abuse of process or would be unnecessary to secure the ends of justice

The Court invoked Section 482 of the Code of Criminal Procedure, read with Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, as the basis for exercising inherent jurisdiction to quash proceedings, including in cases involving non-compoundable offences

It distinguished that power from statutory compounding under Section 320 CrPC and relied on Narinder Singh & Ors. v. State of Punjab & Anr., (2014) 6 SCC 466, which holds that the High Court may quash non-compoundable offences following settlement where doing so serves the ends of justice or prevents abuse of process.

The power must be exercised cautiously, with attention to the nature and gravity of the offences, the likelihood of conviction, and the stage of proceedings

The Court considered the dispute to have arisen between the complainant and the accused and found that the parties had settled it with the intervention of family elders, without compulsion or coercion

It noted that the accused persons’ roles were not clearly established and that the complainant had not stated a clear direct nexus between them and the alleged offences; it therefore considered the prospect of conviction remote

Applying the principles in Narinder Singh, the Court concluded that continuing the prosecution after the settlement would be unnecessary and would amount to an abuse of process

It quashed the proceedings in C.C. No. 743/2026, arising from Crime No. 233/2024 and pending before the II JMFC, Belagavi, for the offences charged under the BNS; I.A. No. 2/2026 was allowed accordingly