Quashing of Criminal Proceedings Permitted via Compounding where Parties Amicably Settle Financial Fraud Under IPC Section 420

The Applicant filed an application to quash a charge-sheet dated 15.11.2024 and a summoning order dated 12.05.2026 issued by the Judicial Magistrate, Gangolihat.

The criminal proceedings (Case No. 112 of 2026) originated from an FIR involving allegations that Respondent No. 3 was defrauded of approximately six lakh rupees through a social media scam related to “Kaun Banega Crorepati (KBC)”.

During the pendency of the matter, the parties filed a Joint Compounding Application (I.A. No. 01 of 2026), asserting that they had amicably resolved the dispute and the duped amount had been returned.

The State opposed the compounding, arguing the offenses were serious and affected society at large.

Whether the criminal proceedings against the Applicant under Sections 420 and 120-B of the IPC should be quashed in light of a private settlement between the parties.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which recognizes the inherent powers of the High Court to make orders necessary to give effect to any order under the Sanhita, to prevent abuse of the process of any Court, or otherwise to secure the ends of justice.

The inherent powers previously exercised under Section 482 of the CrPC regarding the quashing of non-compoundable offenses when parties reach a settlement.

The nature of offenses under Sections 420 (Cheating) and 120-B (Criminal Conspiracy) of the Indian Penal Code.

The Court evaluated the State's objection regarding the gravity of the offense against the fact that the dispute was primarily private/financial in nature.

The Court interacted personally with Respondent No. 3, who confirmed that the entire defrauded amount had been returned and that he had no objection to the quashing of the case.

The Court reasoned that since the victim—who was enticed by an impersonator titled “KBC Rana Pratap Singh”—no longer wished to pursue the matter, continuing the criminal trial would serve no useful purpose.

Under the specific facts and circumstances, the Court determined that quashing the proceedings was necessary to "secure the ends of justice" and "prevent abuse of the process of law".

The court held that the entire proceedings of Criminal Case No. 112 of 2026 arising out of Case Crime No. 01 of 2023 are quashed specifically against the Applicant.

The Criminal Miscellaneous Application filed under Section 528 of the BNSS was disposed of accordingly.