Private family-dispute prosecutions may be quashed upon settlement where the offences are not against the State.

The connected petitions arose from cross-criminal proceedings between family members concerning inter se disputes described as civil in nature.

The prosecutions involved allegations including trespass, assault, intimidation and offences against women, and were pending before the competent court at Hunsur

The parties filed joint applications under Sections 320 and 482 of the Code of Criminal Procedure, supported by affidavits stating that the underlying civil dispute had attained finality and that they had voluntarily settled the criminal cases.

The parties appeared before the High Court and confirmed their understanding of the affidavits

Whether the parties’ settlement justified compounding the offences and quashing the connected criminal proceedings

Whether the High Court could give effect to the settlement in exercise of its powers under Sections 320 and 482 Cr.P.C.

The Court considered Section 320 Cr.P.C., which governs the compounding of specified offences, read with Section 482 Cr.P.C., which preserves the High Court’s inherent power to prevent abuse of process and secure the ends of justice.

Relying on Gian Singh v. State of Punjab and Another, (2012) 10 SCC 303, the Court recognised its power to act on a settlement in an appropriate case involving a private dispute

The Court accepted the parties’ joint affidavits and noted that the parties were family members, the dispute was civil in nature, and the criminal cases arose between private parties rather than from offences against the State

As the parties had voluntarily settled and appeared before the Court to confirm their understanding of the settlement, the Court considered it appropriate to allow the applications under Sections 320 and 482 Cr.P.C.

It quashed the criminal cases registered against the parties in the connected proceedings