Non-heinous criminal proceedings may be quashed where parties have amicably settled and conviction is unlikely.

FIR No. 15/2021 was registered against the petitioner under Sections 452, 382, 427, 504, 506 and 201 IPC at the instance of respondent No. 3.

The investigation resulted in Challan/Final Report No. 32/2021, pending before the Munsiff (JMIC), Mahore.

During the proceedings, the petitioner and respondent No. 3 entered into a written compromise dated 23 April 2026.

Their statements were recorded before the Registrar Judicial, and respondent No. 3 stated that he had no objection to quashing the FIR and consequential proceedings.

The petitioner sought quashing under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Whether the criminal proceedings could be quashed on the basis of the parties’ compromise.

Whether, in the circumstances of this case, continuation of the proceedings would serve a useful purpose or amount to an abuse of the process of court.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, was invoked as the basis for the High Court’s quashing jurisdiction.

Applying Narinder Singh v. State of Punjab, (2014) 6 SCC 466, the Court noted that proceedings involving heinous or serious offences, offences of mental depravity, or specified public-interest offences should not be quashed merely on compromise; by contrast, proceedings with an overwhelmingly or predominantly private or civil character may be quashed where the parties have resolved their dispute.

The Court must also consider whether the prospect of conviction is remote and whether continuing the proceedings would cause oppression, prejudice or injustice.

The Court found that the alleged offences were not heinous in nature and that the complainant and petitioner had amicably settled their dispute.

Respondent No. 3’s recorded statement confirmed that he had no objection to quashing.

In light of the compromise, the Court considered the chances of conviction bleak and concluded that continuing the proceedings would serve no useful purpose and would cause injustice to the parties.

The petition was disposed of accordingly.