Proceedings under the SC/ST Act may be quashed when allegations arise from a settled private civil dispute.

The petitioners and respondent no. 2 were property dealers operating in the same locality and had a pre-existing dispute concerning a property in Sharma Enclave.

During the dispute, the petitioners allegedly abused respondent no. 2 using caste-related remarks on 17 October 2024.

On the basis of information allegedly received from other persons, respondent no. 2 lodged FIR No. 0562/2024 dated 28 October 2024 at P.S. Prem Nagar, Delhi, under Section 351(3) of the Bharatiya Nyaya Sanhita, 2023 and Sections 3(1)(r) and 3(1)(s) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (“SC/ST Act”).

Investigation was completed and a chargesheet had been filed.

During the proceedings, the parties entered into a Deed of Compromise/Memorandum of Understanding dated 1 September 2026.

Respondent no. 2 stated that he had not personally heard any caste-related slurs and that the FIR was based on hearsay information; he also consented to quashing of the proceedings.

Whether the High Court could exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, corresponding to Section 482 of the Code of Criminal Procedure, 1973, to quash the FIR and consequential proceedings on the basis of a settlement between the parties.

Whether proceedings involving Sections 3(1)(r) and 3(1)(s) of the SC/ST Act could be quashed where the dispute was essentially private and property-related, the alleged caste remarks were not directly heard by the complainant, and continuation of the prosecution would not advance the object of the SC/ST Act.

Whether the parties’ settlement made the possibility of conviction remote and rendered continuation of the criminal proceedings an abuse of the process of law.

The Court applied Section 528 of the BNSS, corresponding to Section 482 CrPC, which preserves the High Court’s inherent power to prevent abuse of process and secure the ends of justice.

It relied on Gian Singh v. State of Punjab, (2012) 10 SCC 303, for the principle that criminal proceedings involving offences with an overwhelmingly civil or private character may be quashed following settlement where continuation would be futile and defeat the ends of justice.

It further relied on Narinder Singh v. State of Punjab, (2014) 6 SCC 466, which holds that such power must be exercised sparingly, but may be used where the dispute is personal, the possibility of conviction is remote, and continuation would cause oppression or injustice; the power ordinarily should not be exercised for heinous offences or offences having a serious impact on society.

The Court also applied Ramavatar v. State of Madhya Pradesh, Criminal Appeal No. 1393/2011, decided on 25 October 2024, which recognises that proceedings under the SC/ST Act may be quashed where the dispute is primarily private or civil, the offence was not committed on account of the victim’s caste, and quashing would not undermine the statute’s underlying purpose.

The Court found that the genesis of the dispute was a property-related disagreement between persons engaged in the same business and living in the same vicinity, making the controversy predominantly civil and private in character.

Respondent no. 2 confirmed that he had not directly heard the alleged casteist remarks and that the FIR was based on information supplied by other persons.

In view of this statement, the settlement, and respondent no. 2’s lack of objection to quashing, the Court considered the likelihood of conviction remote.

It further held that the alleged conduct did not constitute a heinous offence and that quashing would not defeat the object of the SC/ST Act because the alleged remarks were not shown to have been made on account of the complainant’s caste.

Applying the principles in Gian Singh, Narinder Singh, and Ramavatar, the Court concluded that continuation of the prosecution would serve no public interest and would amount to an abuse of process.

The parties were directed to remain bound by the settlement terms.

The petitioners were further directed to deposit ₹15,000 as costs with the Delhi High Court Bar Association Fund.

The petition and pending application were accordingly disposed of.