Quashing of non-compoundable criminal proceedings under Section 528 BNSS is permissible upon voluntary compromise between parties.

The petitioner, Sajid Hussain Khan, filed a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) seeking the quashment of FIR Crime No. 01/2024 registered at Police Station Basoda Dehat, District Vidisha.

The FIR alleged offenses under Sections 406, 407, 420, 467, 468, and 471 of the Indian Penal Code (IPC).

During the pendency of the proceedings, the petitioner and respondent No. 2 (the complainant) entered into a voluntary settlement and filed applications for compounding the offenses (I.A. No. 5678/2026 and I.A. No. 5680/2026).

The Principal Registrar of the High Court verified the compromise, confirming that the agreement was reached voluntarily without threat or coercion.

Whether the High Court can exercise its inherent powers under Section 528 of the BNSS to quash criminal proceedings for non-compoundable offenses on the basis of a voluntary compromise between the parties.

Section 528 of the BNSS (corresponding to Section 482 of the CrPC), which preserves the High Court's inherent power to prevent abuse of the process of law.

Gian Singh v. State of Punjab (2012) and Narinder Singh v. State of Punjab (2014), which established that even in non-compoundable cases, proceedings may be quashed if a compromise is reached and the continuation of trial would be futile.

The principle that a "Lean Compromise is better than a Fat Law Suit".

The court observed that the parties had settled their disputes amicably and the Principal Registrar had verified the authenticity of the compromise.

In evaluating the necessity of continuing the trial, the court reasoned that since the complainant no longer intended to pursue the case, any further trial would be a "futile exercise" that would serve no purpose and waste the valuable time of the judiciary.

The court determined that invoking its inherent powers was justifiable to preserve the "bonhomie" created by the settlement and to prevent an unnecessary drain on judicial resources.

The court held that the parties are permitted to compound the offenses to serve the interest of justice and prevent the abuse of the legal process.

The court further directed that the applicant be released immediately if not required in any other case.