Quashing of criminal proceedings under BNSS Section 528 is permissible upon compromise in non-heinous private disputes.

The ten petitioners filed a Criminal Miscellaneous Petition seeking to quash the First Information Report (FIR) and entire criminal proceedings related to Dhansar P.S. Case No. 33 of 2026

The case involved allegations under Sections 190, 191(2), 191(3), 126(2), 115(2), 118(2), 109(1), 351(2), 352 of the Bharatiya Nyaya Sanhita (BNS), 2023, and Section 27 of the Arms Act

The parties subsequently entered into an amicable settlement outside of court with the help of well-wishers and relatives

They filed Interlocutory Application No. 7907 of 2026, supported by affidavits from the petitioners, the informant (O.P. No. 2), and the victim (O.P. No. 3), stating that the dispute was private in nature, arising from a demand for money

The State expressed no objection to the quashing in light of the compromise

1. Whether the High Court should exercise its inherent power to quash criminal proceedings involving non-compoundable offences based on a private settlement between the parties

2. Whether the continuation of proceedings would amount to an abuse of the process of law when the chances of conviction are remote due to a compromise

Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (corresponding to Section 482 of the Cr.P.C.), which preserves the High Court's inherent power to prevent abuse of process or secure the ends of justice

Narinder Singh and Others v. State of Punjab Another (2014) 6 SCC 466, which mandates that while heinous crimes (murder, rape) should not be quashed based on settlement, cases of a predominant civil or private character, where the possibility of conviction becomes "remote and bleak" due to compromise, ought to be quashed to prevent prejudice to the accused

The Court examined the nature of the allegations and the subsequent settlement. It noted that the genesis of the occurrence was a "petty dispute regarding demand of payment of money," characterizing it as a private matter rather than a crime against society

Applying the Narinder Singh framework, the Court found that the offences were not "heinous" nor involved "mental depravity"

The Court reasoned that since the victim and informant no longer intended to testify against the petitioners, the likelihood of conviction was "remote and bleak"

Consequently, forcing the petitioners to undergo a trial despite a "full and complete settlement" would constitute "extreme injustice" and an "abuse of process of law"

The Court allowed the Criminal Miscellaneous Petition and quashed the entire criminal proceedings, including the FIR in Dhansar P.S. Case No. 33 of 2026, against all ten petitioners

Interlocutory Application No. 7907 of 2026 was disposed of accordingly